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Finally, petitioner advances several contentions phrased in
terms of the prescribed verification that the requirements of any
applicable law or administrative procedure were met. These
claims are to a certain degree interrelated with his arguments
couched in terms of the assessment. To the extent that there
exists a different emphasis, suffice it to say that section
6330(c)(1) mandates neither that the Appeals officer rely on a
particular document in satisfying the verification requirement
nor that the Appeals officer actually give the taxpayer a copy of
the verification upon which he or she relied. Craig v.
Commissioner, supra at 262; Nestor v. Commissioner, supra at 166.
Moreover, we have specifically held that it is not an abuse of
discretion for an Appeals officer to rely on Form 4340 to comply
with section 6330(c)(1). Nestor v. Commissioner, supra at 166;
Davis v. Commissioner, supra at 41.
Thus, with respect to those issues enumerated in section
6330(c)(2)(A) and subject to review in collection proceedings for
abuse of discretion, petitioner has not raised any spousal
defenses, valid challenges to the appropriateness of the
collection action, or collection alternatives. As this Court has
noted in earlier cases, Rule 331(b)(4) states that a petition for
review of a collection action shall contain clear and concise
assignments of each and every error alleged to have been
committed in the notice of determination and that any issue not
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