- 11 - 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 thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011