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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 petitioners’
demands and allegations regarding the authority of the
individuals issuing the notices of tax lien, tax lien filing, and
intent to levy are meritless for reasons substantially identical
to those just discussed in connection with the notices of
deficiency. The Secretary or his delegate (including the
Commissioner) may issue these 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.; Deleg. Order No. 191 (Rev. 3, June 11,
2001); Deleg. 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 that such collection
notices be signed. Everman v. Commissioner, supra.
Petitioners have claimed that no valid assessments support
the proposed collection and have asserted that they should have
been provided with copies of Form 23C, Summary Record of
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