- 15 -
somber reasoning and copious citation of precedent; to do so
might suggest that these arguments have some colorable merit.”).
3. Review for Abuse of Discretion
Petitioner has also made various arguments relating to
aspects of the assessment and collection procedures that we
review for abuse of discretion. Action constitutes an abuse of
discretion under this standard where arbitrary, capricious, or
without sound basis in fact or law. Woodral v. Commissioner, 112
T.C. 19, 23 (1999).
As a threshold matter, we point out that petitioner’s
demands and allegations regarding the authority of the individual
issuing the notice of intent to levy are meritless for reasons
substantially identical to those just discussed in connection
with the notice of deficiency. The Secretary or his delegate
(including the Commissioner) may issue collection notices, and
authority to so issue notices regarding liens and to levy upon
property has in turn been delegated to a host of pertinent
collection and compliance personnel. Secs. 6320(a), 6330(a),
7701(a)(11)(B) and 12(A)(i), 7803(a)(2); secs. 301.6320-1(a)(1),
301.6330-1(a)(1), Proced. & Admin. Regs.; Delegation Order No.
191 (Rev. 3; June 11, 2001); Delegation Order No. 196 (Rev. 4;
Oct. 4, 2000); see also Craig v. Commissioner, 119 T.C. 252, 263
(2002); Everman v. Commissioner, T.C. Memo. 2003-137.
Additionally, we note that there exists no statutory requirement
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