- 18 -
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
computerized transcripts of account. See Davis v. Commissioner,
115 T.C. at 41; 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 liabilities for 1997 and 1998. 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.
* * *
In particular, the computerized transcripts of account on which
the Appeals officer relied during the administrative process, as
well as the Forms 4340, show that respondent sent petitioner
notices of balance due on the same date that respondent made
assessments against petitioner for the tax, addition to tax, and
6(...continued)
forms to his Amended Objection to respondent’s motion.
Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 NextLast modified: May 25, 2011