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to collection issues, including spousal defenses, the
appropriateness of respondent’s intended collection action, and a
possible alternative to collection. Petitioner questioned the
appropriateness of respondent’s proposed collection action by
questioning whether the Appeals officer had satisfied the
verification requirement of section 6330(c)(1). Petitioner
contends that respondent used incorrect forms for the notice and
demand and otherwise failed to meet the requirement because the
Secretary did not personally verify the liability.
At the Appeals conference, petitioner was provided with a
literal transcript of his account which detailed information
underlying the assessment of the tax in question. Petitioner
does not question whether all of the steps had been taken or
performed. In effect, he questions the genuineness or
authenticity of the documents respondent used to meet the
statutory requirements. Section 6330(c)(1) does not require the
Commissioner to rely on a particular document to satisfy the
verification requirement. Wagner v. Commissioner, T.C. Memo.
2002-180; see also Roberts v. Commissioner, 118 T.C. 365, 371
(2002). In addition, it has been held that “‘[t]he form on which
a notice and assessment and demand for payment is made is
irrelevant as long as it provides the taxpayer with all the
information required under * * * [section 6303].’” Hughes v.
United States, 953 F.2d 531, 536 (9th Cir. 1992) (quoting Elias
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