- 8 - dated April 19, 2002, for 1996, 1997, and 1998 or that he received it. His arguments focus solely on the adequacy of the notice. Among his arguments, petitioner claims that the notice was not delivered by an authorized party, was not signed, and showed no deficiency. Petitioner’s assertions, however, are completely without merit. A notice of deficiency is validly issued if sent by certified or registered mail to the taxpayer’s last known address. Sec. 6212(a) and (b). There is no requirement that the notice be specially delivered by an authorized agent. The Commissioner is also under no obligation to sign a statutory notice of deficiency in order for the notice to be valid. Sec. 6212; see Commissioner v. Oswego Falls Corp., 71 F.2d 673, 677 (2d Cir. 1934), affg. 26 B.T.A. 60 (1932); Pendola v. Commissioner, 50 T.C. 509, 514 (1968); Stone v. Commissioner, T.C. Memo. 1998-314. Moreover, petitioner’s interpretation that the notice he received represented a mere “suggestion” to pay tax is baseless given the clarity of the language used.4 The notice was clearly labeled “Notice of Deficiency”, stated that additional amounts were owed, and provided a detailed listing of the deficiencies determined by 4 Sec. 7522(a) provides insight as to the content required in a notice of deficiency by stating that “Any notice to which this section applies shall describe the basis for, and identify the amounts (if any) of, the tax due, interest, additional amounts, additions to the tax, and assessable penalties included in such notice.” However, sec. 7522(a) also provides that an inadequate description “shall not invalidate such notice.”Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007