Glen A. Blair - Page 9




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               Section 6330(c)(1) does not require the Commissioner to rely           
          on a particular document to satisfy the verification requirement            
          imposed therein.  Weishan v. Commissioner, T.C. Memo. 2002-88;              
          Lindsey v. Commissioner, T.C. Memo. 2002-87; Tolotti v.                     
          Commissioner, T.C. Memo. 2002-86; Duffield v. Commissioner, T.C.            
          Memo. 2002-53; Kuglin v. Commissioner, T.C. Memo. 2002-51.  In              
          this regard, we observe that the Form 4340 on which the Appeals             
          officer 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 also contends that he never received a notice and           
          demand for payment for 1997.  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 Form 4340 that respondent provided to the Court shows that              
          notices of balance due were issued to petitioner on October 30,             
          2000, and December 4, 2000.  A notice of balance due constitutes            
          a notice and demand for payment within the meaning of section               






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