- 15 -
Commissioner, supra; Kuglin v. Commissioner, supra.6
Petitioner has not alleged any irregularity in the
assessment procedure that would raise a question about the
validity of the assessment or the information contained in the
Form 4340. See Davis v. Commissioner, 115 T.C. at 41; Mann v.
Commissioner, T.C. Memo. 2002-48. Accordingly, we hold that the
Appeals officer satisfied the verification requirement of section
6330(c)(1). Cf. Nicklaus v. Commissioner, 117 T.C. 117, 120-121
(2001).
Petitioner also contends that he never received a notice and
demand for payment of his tax liability for 1998. The
requirement that the Secretary issue a notice and demand for
payment is set forth in section 6303(a), which provides in
pertinent part:
SEC. 6303(a). General Rule.-–Where it is not
otherwise provided by this title, the Secretary shall,
as soon as practicable, and within 60 days, after the
making of an assessment of a tax pursuant to section
6203, give notice to each person liable for the unpaid
tax, stating the amount and demanding payment thereof.
* * *
In particular, the Form 4340 on which the Appeals officer relied
6 To the extent that petitioner may still be arguing that
the Appeals officer failed to provide him with a copy of the
verification, we note that sec. 6330(c)(1) does not require that
the Appeals officer provide the taxpayer with a copy of the
verification at the administrative hearing. Nestor v.
Commissioner, 118 T.C. 162, 166 (2002). In any event, the
Appeals officer provided petitioner with a copy of Form 4340 for
the taxable year 1998. Indeed, petitioner attached a copy of
this form as an exhibit to his petition.
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