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amount of the assessment.6 See sec. 301.6203-1, Proced. & Admin.
Regs. The MFTRA-X transcripts further indicate that the
examination assessments were made on September 11, 1989, with
respect to 1984, 1985, and 1986, and June 11, 1990, as to 1987.
Petitioner next contends that even if the assessments were
properly made, he was not given notice thereof as required by
section 6303. He also claims he was not given proper notice of
intent to levy as required by section 6331. Both claims are
meritless. Forms 4340 for each of the years at issue are in the
record and show that petitioner was sent “Statutory Notices of
Intent to Levy” on March 18, 1991, and June 19, 1995. Either of
these notices is sufficient to satisfy the notice requirement of
section 6331. In addition, a notice of intent to levy can
satisfy the notice requirement of section 6303. Hughes v. United
States, 953 F.2d 531, 536 (9th Cir. 1992); Standifird v.
Commissioner, supra. Petitioner’s contentions concerning his
notice under sections 6303 and 6331 demonstrate no abuse of
discretion.
Petitioner’s contention that he did not receive notices of
deficiency with respect to the examination assessments likewise
has no merit. By signing Forms 4549 and CP-2000, petitioner
consented to the immediate assessment of the tax liabilities set
6 The MFTRA-X transcripts for 1985 and 1986 introduced as
exhibits are illegible in some respects, but legible copies are
contained elsewhere in the record.
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