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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 was previously delegated to
District Directors and Directors of Service Centers, has since
been redelegated consistent with the restructuring of the IRS,
and may in turn be redelegated to officers or employees under the
supervision of persons so authorized. Secs. 301.6212-1(a),
301.7701-9(b) and (c), Proced. & Admin. Regs.; Deleg. Order No.
193 (Rev. 6, Nov. 8, 2000); see also Nestor v. Commissioner, 118
T.C. at 165.
Accordingly, because petitioners received valid notices of
deficiency and did not timely petition for redetermination, they
are precluded under section 6330(c)(2)(B) from disputing their
underlying 1999 and 2000 liabilities in this proceeding. Their
remaining contentions generally challenging the “existence” of
any statute imposing or requiring them 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 somber reasoning and copious citation of
precedent; to do so might suggest that these arguments have some
colorable merit.”).
C. Review for Abuse of Discretion
Petitioners have also made various arguments relating to
aspects of the assessment and collection procedures that we
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