Shade D. Coleman III and Maria M. Coleman - Page 9

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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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