Edward W. Clough - Page 8

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         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.”                  

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