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Secretary did not prepare or issue the notices of deficiency and
because petitioners did not receive a copy of the order
delegating authority from the Secretary to the Director of the
Service Center who prepared and issued the notices.
Petitioners’ contention lacks merit. The Secretary or his
or her delegate may issue notices of deficiency. Secs. 6212(a),
7701(a)(11)(B) and (12)(A)(i); see Nestor v. Commissioner, 118
T.C. 162, 165-166 (2002). The Secretary’s authority to issue
notices of deficiency was delegated to the District Director and
also to the Director of the Service Center who issued the notices
of deficiency in this case. See Nestor v. Commissioner, supra;
Stamos v. Commissioner, 95 T.C. 624, 630-631 (1990), affd.
without published opinion 956 F.2d 1168 (9th Cir. 1992); Kellogg
v. Commissioner, 88 T.C. 167, 172 (1987); Perlmutter v.
Commissioner, 44 T.C. 382, 385 (1965), affd. 373 F.2d 45 (10th
Cir. 1967); secs. 301.6212-1(a), 301.7701-9(b), Proced. & Admin.
Regs. A taxpayer may contest the existence or amount of his or
her underlying tax liability at a section 6330(b) hearing only if
the taxpayer did not receive a notice of deficiency for or
otherwise have an opportunity to dispute that tax liability.
Sec. 6330(c)(2)(B); Goza v. Commissioner, 114 T.C. 176, 182
(2000). Section 6330(c)(2)(B) bars petitioners from contesting
the existence or amount of their tax liabilities for 1996-2001 in
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