Crevenne C. and Barbara A. Carrillo - Page 23

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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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