- 17 -
officer and attached to respondent’s Declaration 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.6 Petitioner
has not alleged any irregularity in the assessment procedure that
would raise a legitimate question about the validity of the
assessment or the information contained in the Form 4340. See
Davis v. Commissioner, 115 T.C. 35, 41 (2000); 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
“statutory” 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:
6 To the extent that petitioner may 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); sec. 301.6330-1(e)(1),
Proced. & Admin Regs. In any event, both the Appeals officer and
respondent’s counsel provided petitioner with a Form 4340 for the
taxable year in issue.
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