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has met the burden of production, and petitioner is liable for an
addition to tax for failure to file under section 6651(a)(1) of
$9,949 and $5,447 for 2001 and 2002, respectively, and an
addition to tax under section 6654 for failure to pay estimated
tax of $1,590 and $728 for 2001 and 2002, respectively.
D. Delegated Authority
As a final argument, petitioner asserts that the person who
issued the notice of deficiency for the years at issue lacked
proper authority. It is well settled the Secretary or his
delegate may issue notices of deficiency. Secs. 6212(a),
7701(a)(11)(B) and (12)(A)(i); see Pendola v. Commissioner, 50
T.C. 509, 512-514 (1968). For these reasons and petitioner’s
failure to provide authority to the contrary, the Court finds
petitioner’s argument is without merit.
The Court, in reaching its holding, has considered all
arguments made and concludes that any arguments not mentioned
above are moot, irrelevant, or without merit.
To reflect the foregoing,
Decisions will be entered
for respondent.
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Last modified: May 25, 2011