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Commissioner, supra; Duffield v. Commissioner, supra; Kuglin v.
Commissioner, supra.
Petitioners have not alleged any irregularity in the
assessment procedure that would raise a question about the
validity of the assessments or the information contained in the
transcript of account. See Nestor v. Commissioner, supra; 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).
Petitioners also contend that they 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 was provided to petitioners during the
administrative process shows that respondent issued to
petitioners a notice of balance due on the same date that
respondent entered assessments against petitioners for the tax,
addition to tax, and accuracy-related penalty set forth in the
notice of deficiency. We hold that a notice of balance due
constitutes a notice and demand for payment within the meaning of
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