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notice, making clear that this document was received. To the
extent that petitioner has argued that she should nonetheless be
entitled to challenge her underlying liabilities on grounds that
the notice was invalid, due to a lack of a delegation of
authority from the Secretary to the individual at the Ogden
Service Center signing the notices, this contention is without
merit.
The Secretary or his delegate may issue notices of
deficiency. Secs. 6212(a), 7701(a)(11)(B) and (12)(A)(i). The
Secretary’s authority in this matter has been delegated to
District Directors and Directors of Service Centers, and may in
turn be redelegated to officers or employees under the
supervision of such persons. Secs. 301.6212-1(a), 301.7701-9(b)
and (c), Proced. & Admin. Regs.; see also Nestor v. Commissioner,
118 T.C. at 165.
Hence, because petitioner received a valid notice of
deficiency and did not timely petition for redetermination, she
is precluded under section 6330(c)(2)(B) from disputing her
underlying tax liabilities in this proceeding. Her remaining
contentions generally challenging the “existence” of any statute
imposing or requiring her to pay income tax warrant no further
comment. See Crain v. Commissioner, 737 F.2d 1417, 1417 (5th
Cir. 1984) (“We perceive no need to refute these arguments with
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