Harold E. Call - Page 18

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          Regs.  A taxpayer receiving a copy of Form 4340 has been provided           
          with all the documentation to which he or she is entitled under             
          section 6203 and section 301.6203-1, Proced. & Admin. Regs.                 
          Roberts v. Commissioner, supra at 370 n.7.  This Court likewise             
          has upheld collection actions where taxpayers were provided with            
          literal transcripts of account (so-called MFTRAX).  See, e.g.,              
          Frank v. Commissioner, T.C. Memo. 2003-88; Swann v. Commissioner,           
          T.C. Memo. 2003-70.  The notice of determination states                     
          “certified transcripts (Form 4340)” were mailed to petitioner.              
          Petitioner challenges that statement on brief with the assertion:           
          “The so-called transcripts were not properly certified and were             
          not signed by an Assessment Officer as required by law.”  The               
          Court concludes that petitioner’s complaints regarding the                  
          assessments and verification are meritless.                                 
               Petitioner has denied receiving the notice and demand for              
          payment that section 6303(a) establishes should be given within             
          60 days of the making of an assessment.  However, a notice of               
          balance due constitutes a notice and demand for payment within              
          the meaning of section 6303(a).  Craig v. Commissioner, supra at            
          262-263.  The Forms 4340 indicate that petitioner was sent                  
          notices of balance due for each of the tax years involved.                  
               Finally, at trial petitioner raised an issue regarding                 
          proper notification of the filing of the notice of tax lien.  His           







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