- 13 -
117, 120-121 (2001).
Petitioner also contends that he never received a notice and
demand for payment for 1992. 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 on which the Appeals officer
relied during the administrative process shows that respondent
sent petitioner a notice and demand for payment on the same date
that respondent made assessments against petitioner for the tax
and additions to tax determined in the notice of deficiency.
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).
Petitioner has failed to raise a spousal defense, make a
valid challenge to the appropriateness of respondent’s intended
collection action, or offer alternative means of collection.
These issues are now deemed conceded. Rule 331(b)(4). In the
absence of a valid issue for review, we conclude that respondent
is entitled to judgment as a matter of law sustaining the notice
of determination dated June 8, 2001.
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