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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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