Stanley Howard - Page 8




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          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.                                   




















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