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validity of the assessment or the information contained in the
Form 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 liability for 1997. 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
6203, give notice to each person liable for the unpaid
tax, stating the amount and demanding payment thereof.
* * *
In particular, the Form 4340 on which the Appeals officer relied
during the administrative process shows that respondent sent
petitioner a notice of balance due on the same date that
respondent made assessments against petitioner for the tax and
accuracy-related penalty determined in the notice 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); Weishan v.
Commissioner, supra; see also Hansen v. United States, 7 F.3d
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