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Lindsey v. 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 transcripts of account 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
transcripts of account. See Nestor v. Commissioner, supra at
167; 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 the years in question. 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
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