-18-
v. Commissioner, T.C. Memo. 2002-204; Howard v. Commissioner,
T.C. Memo. 2002-81; Mann v. Commissioner, T.C. Memo. 2002-48, we
hold that: (1) The assessments were valid, Kuglin v.
Commissioner, supra; see also Duffield v. Commissioner, T.C.
Memo. 2002-53; and (2) the Appeals officer satisfied the
verification requirement of section 6330(c)(1), Yacksyzn v.
Commissioner, T.C. Memo. 2002-99; cf. Nicklaus v. Commissioner,
117 T.C. 117, 120-121 (2001). Petitioner has not demonstrated in
this proceeding any irregularity in the assessment procedure that
would raise a question about the validity of the assessment or
the information contained in Forms 4340.
Second, petitioner alleges that no statutory notice and
demand for payment was sent to him. We disagree. “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.” Sec. 6303(a). If mailed,
this notice and demand is required to be sent to the taxpayer’s
last known address. Id. Forms 4340 show that respondent sent
petitioner notices of balance due on the same dates that
respondent made assessments against petitioner for the subject
years. A notice of balance due constitutes a notice and demand
for payment under section 6303(a). Schaper v. Commissioner, T.C.
Memo. 2002-203. In addition, petitioner received numerous final
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