John Thurman Horejs - Page 11

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          Commissioner, T.C. Memo. 2002-87; Tolotti v. Commissioner, T.C.             
          Memo. 2002-86; Duffield v. Commissioner, T.C. Memo. 2002-53;                
          Kuglin v. Commissioner, T.C. Memo. 2002-51.  In this regard, we             
          observe that the Forms 4340 on which the Appeals officer relied             
          contained all the information prescribed in section 301.6203-1,             
          Proced. & Admin. Regs.  See Weishan v. Commissioner, supra;                 
          Lindsey v. Commissioner, supra; Tolotti v. Commissioner, supra;             
          Duffield v. Commissioner, supra; Kuglin v. Commissioner, supra.             
              Petitioner has not alleged any irregularity in the                     
          assessment procedure that would raise a question about the                  
          validity of the assessments or the information contained in the             
          Forms 4340.  See Davis v. Commissioner, 115 T.C. 35, 41 (2000);             
          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 for 1995 or 1996.  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.                 
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