Anthony M. Davich - Page 18

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               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            

          forms to his Amended Objection to respondent’s motion.                      

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