Michael Craig v. Commissioner - Page 18




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          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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