- 9 - 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.Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011