- 12 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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