Ginger Harmornick - Page 11

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          validity of the assessments or the information contained in the             
          Forms 4340.  See Davis v. Commissioner, supra 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            
               Petitioner also contends that the Appeals officer failed to            
          provide her with requested documents such as a summary record of            
          assessment.  We note that section 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, as                   
          previously discussed, the record shows that the Appeals officer             
          provided petitioner with Forms 4340 for all of the years in                 
               Petitioner has failed to raise a spousal defense, make a               
          valid challenge to the appropriateness of respondent’s intended             
          collection action, or offer alternative means of collection.                
          These issues are now deemed conceded.  Rule 331(b)(4).  In the              
          absence of a valid issue for review, we conclude that respondent            
          is entitled to judgment as a matter of law sustaining the notice            
          of determination dated August 28, 2000.4                                    

               4  Petitioner has not expressly challenged the existence or            
          amount of her underlying tax liabilities in this collection                 
          review proceeding.  However, to the extent that one might regard            

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