Robert & Polly A. Gatlos - Page 11

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          it was not signed by the Commissioner.  Again, petitioners’                 
          argument has no merit.                                                      
               This Court has repeatedly rejected the argument that the               
          Commissioner is required to sign a final notice.  See, e.g.,                
          Craig v. Commissioner, 119 T.C. at 263.  There is no statutory              
          requirement that a final notice of intent to levy must be signed.           
          Everman v. Commissioner, supra.  Moreover, even though there is             
          no statutory requirement that the notice be signed, the final               
          notice of intent to levy in this case was issued and executed by            
          Revenue Officer Michael Sutton to whom the Commissioner had                 
          delegated the requisite authority.                                          
               The petition does not set forth any other assignments of               
          error with respect to the notice of determination.  Any other               
          argument made by petitioners before or during the hearing was               
          frivolous, was not raised in the petition, and/or is deemed to be           
          conceded.  Rule 331(b)(4).  We conclude, therefore, that there              
          are no genuine issues of material fact and that respondent is               
          entitled to the entry of a decision in this case as a matter of             
          law.                                                                        
          B.  Section 6673 Penalty                                                    
               Section 6673(a)(1) authorizes this Court to require a                  
          taxpayer to pay to the United States a penalty, not to exceed               
          $25,000, if it appears that the taxpayer has instituted or                  
          maintained a proceeding primarily for delay, or that the                    






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