- 8 - not prejudiced. See Nestor v. Commissioner, 118 T.C. 162, 167 (2002). In this case, petitioner was provided with a copy of the Form 4340 prior to trial. However, petitioner did not allege any irregularities in the assessment procedure. Petitioner also did not present any evidence at trial or otherwise show any irregularity in the assessment procedure. Accordingly, we sustain respondent’s determination that the collection action should proceed. Additionally, petitioner has not alleged that the proposed method of collection is inappropriate. Neither has petitioner offered any alternative means of collection, nor has he raised any spousal defenses. Accordingly, we hold for respondent. See Lunsford v. Commissioner, 117 T.C. 183 (2001). Accordingly, Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8
Last modified: May 25, 2011