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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.
* * *
In particular, the Forms 4340 show that respondent sent
petitioner notices of balance due on the same dates that
respondent made assessments against petitioner for the taxes and
accuracy-related penalties determined in the notices of
deficiency. A notice of balance due constitutes a notice and
demand for payment within the meaning of section 6303(a). See,
e.g., Hughes v. United States, 953 F.2d 531, 536 (9th Cir. 1992);
Schaper v. Commissioner, T.C. Memo. 2002-203; Weishan v.
Commissioner, supra; see also Hansen v. United States, 7 F.3d
137, 138 (9th Cir. 1993). In addition, other notices were sent
to petitioner, at least one of which (the final notice, discussed
supra D) petitioner received; likewise, petitioner received the
Forms 4340. Such notices and forms were sufficient to constitute
notice and demand within the meaning of section 6303(a) because
they informed petitioner of the amount owed and requested
payment. Standifird v. Commissioner, supra; Hack v.
Commissioner, T.C. Memo. 2002-244; Hack v. Commissioner, T.C.
Memo. 2002-243; see Elias v. Connett, 908 F.2d 521, 525 (9th Cir.
1990) (“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 required under 26 U.S.C. � 6303(a).”).
Finally, petitioner has failed to raise a spousal defense.
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