- 11 -
transcript of account. See Davis v. Commissioner, supra 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 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.
* * *
The transcript of account that the Appeals officer relied on
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,
addition to 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 137, 138 (9th Cir. 1993).
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