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for 1998. Petitioner admits that he received the notice of
deficiency issued to him for 1998 but contends that it is invalid
because it was not signed by the Secretary, and no delegation
order was provided to him upon request. We reject petitioner’s
argument. The Secretary’s authority to issue notices of
deficiency was delegated to the Service Center Directors. Del.
Ord. 77 (Rev. 28), May 17, 1996; secs. 301.6212-1(a), 301.7701-
9(b), Proced. & Admin. Regs.; see also Nestor v. Commissioner,
118 T.C. 162, 165 (2002). The notice of deficiency petitioner
received was signed by the Memphis Service Center Director.
Section 6212, which requires the Secretary to issue notices of
deficiency, does not require that respondent provide petitioner a
copy of the delegation order. See Nestor v. Commissioner, supra
at 166. Therefore, we conclude that petitioner did receive a
valid notice of deficiency for 1998.
Section 6330(c)(2)(B) provides that a taxpayer may challenge
the existence or amount of his underlying tax liability if he
“did not receive any statutory notice of deficiency for such tax
liability or did not otherwise have an opportunity to dispute
such tax liability.” Because petitioner received a notice of
deficiency for 1998, he may not challenge his underlying tax
liability for that year in a hearing or in this Court. See id.
Petitioner next argues that the assessment against him was
invalid because he did not file a return showing any tax due.
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