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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
(2001).
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
issue.
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
(continued...)
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