- 15 -
Commissioner, supra; Lindsey v. Commissioner, supra; Tolotti v.
Commissioner, supra; Duffield v. Commissioner, supra; Kuglin v.
Commissioner, supra.7
Petitioner has not alleged any irregularity in the
assessment procedure that would raise a question about the
validity of the assessment or the information contained in the
transcript. See Davis v. Commissioner, 115 T.C. 35, 41 (2000);
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).
Petitioner also contends that he never received a notice and
demand for payment of his tax liability 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
7 To the extent that petitioner may still be arguing that
the Appeals officer failed to provide him with a copy of the
verification, we note that sec. 6330(c)(1) does not require that
the Appeals officer provide the taxpayer with a copy of the
verification at the administrative hearing. Nestor v.
Commissioner, 118 T.C. 162, 166 (2002). In any event, the
Appeals officer provided petitioner with a literal transcript for
the taxable year 1997. Indeed, petitioner attached a copy of
this transcript as an exhibit to his petition and/or motion to
dismiss.
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