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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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