Christopher Kiley - Page 22

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          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.11           
               Petitioner has not alleged any irregularity in the                     
          assessment procedure that would raise a legitimate question about           
          the validity of the assessments or the information contained in             
          the Forms 4340.  See Davis v. Commissioner, 115 T.C. 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 he never received a notice and           
          demand for payment of his tax liabilities for 1997 and 1998.  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                  

               11  To the extent that petitioner may be arguing that the              
          Appeals officer failed to provide him with a copy of the                    
          verification, we note that sec. 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); sec. 301.6330-1(e)(1),              
          Proced. & Admin Regs.  In any event, both the Appeals officer and           
          respondent’s counsel provided petitioner with Forms 4340 for the            
          3 taxable years in issue.                                                   

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