Harvey Doyne Perry, Jr. - Page 15

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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            
               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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