William Wilson - Page 12




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          Kuglin v. Commissioner, T.C. Memo. 2002-51.  In this regard, we             
          observe that the Forms 4340 on which the Appeals officers relied            
          contained all the information prescribed in section 301.6203-1,             
          Proced. & Admin. Regs.  See Weishan v. Commissioner, supra;                 
          Lindsey v. Commissioner, supra; Tolotti v. Commissioner, supra;             
          Duffield v. Commissioner, supra; Kuglin v. Commissioner, supra.             
              Petitioner has not alleged any irregularity in the                     
          assessment procedure that would raise a question about the                  
          validity of the assessments or the information contained in the             
          Forms 4340.  See Davis v. Commissioner, supra at 41; Mann v.                
          Commissioner, T.C. Memo. 2002-48.  Accordingly, we hold that the            
          Appeals officers 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 valid                
          notice and demand for payment of the taxes in question.  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.                 
               * * *                                                                  
          The Forms 4340 that the Appeals officers relied on during the               






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