-9-
this proceeding any irregularity in the assessment procedure that
would raise a question about the validity of the assessment or
the information contained in Forms 4340. See Mann v.
Commissioner, supra.
Petitioner further contends that he had not been sent “the
Notice of Assessment.” The record shows otherwise. “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.” Sec. 6303(a).
If mailed, this notice and demand is required to be sent to the
taxpayer’s last known address. Id. Forms 4340 show that
respondent sent petitioner notices of balance due for 1993, 1995,
and 1996. A notice of balance due constitutes a notice and
demand for payment within the meaning of section 6303(a).
Schaper v. Commissioner, T.C. Memo. 2002-203. In addition,
petitioner received numerous final notices (notices of intention
to lien and levy), receipt of which petitioner does not dispute.
These numerous notices were sufficient and met the requirements
of section 6303(a). Hansen v. United States, 7 F.3d 137, 138
(9th Cir. 1993); Hughes v. United States, 953 F.2d 531, 536 (9th
Cir. 1992); Weishan v. Commissioner, supra. “The form on which a
notice of assessment and demand for payment is made is irrelevant
as long as it provides the taxpayer with all the information
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