Lucinda A. Yazzie - Page 14

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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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