- 6 - unlawful takings from our God given, constitutionally protected rights to the property of our labor. The Court agrees with respondent that this correspondence, and the assertions raised therein, are frivolous. OPINION I. Contentions of the Parties Petitioner argues that he does not owe any tax or addition thereto for the 1994 through 2001 taxable years because: (1) The statutory notices of deficiency issued to him by respondent were not valid; (2) the notices of deficiency for the years in issues were not signed by an authorized signer;4 (3) the Form 4549, 4 The notices of deficiency for 1994 through 2000 were signed by Timothy A. Towns, and the notice of deficiency for 2001 was signed by Thomas D. Mathews. Both Mr. Towns and Mr. Mathews signed the notices on behalf of the “Compliance Center, Ogden Service Center”. Under the Internal Revenue Manual, the authority “to sign and send to the taxpayer by registered or certified mail, any notice of deficiency” is delegated to, among other individuals, “Directors, Customer Service Centers” and the later individuals may redelegate the authority “directly to selected individuals within their functional area.” I.R.S. Deleg. Order No. 77 (Rev. 28) (May 17, 1996). This delegation order applied to Mr. Towns and Mr. Mathews. See also discussion infra p. 9. Petitioner did not provide any evidence that Mr. Towns or Mr. Mathews was not an individual to whom the authority to sign notices of deficiency could have been delegated. Generally, the Court does not look behind the notice of deficiency to determine or examine the evidence used, the propriety of the Commissioner’s motives in making the determinations, or to question the administrative policies and procedures leading to a determination. Kantor v. Commissioner, 998 F.2d 1514, 1521 (9th Cir. 1993), affg. and revg. on another issue T.C. Memo. 1990-380; Pasternak v. Commissioner, 990 F.2d 893, 898 (6th Cir. 1993), affg. Donahue v. Commissioner, T.C. Memo. 1991-181; Greenberg’s Express, Inc. v. Commissioner, 62 T.C. 324, 327 (1974); Corcoran v. Commissioner, T.C. Memo. 2002- (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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