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taxes.” He argues that there is no proof of mailing by
respondent of the Notices of Assessment required by section 6303.
The record shows otherwise. “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.” Sec. 6303(a). If mailed, this
notice and demand is required to be sent to the taxpayer’s last
known address. Id. Forms 4340 show that respondent sent
petitioner notices of balance due on the same dates that
respondent made assessments against petitioner for 1990 and 1991.
A notice of balance due constitutes a notice and demand for
payment within the meaning of section 6303(a). Schaper v.
Commissioner, T.C. Memo. 2002-203. In addition, petitioner in
this case received numerous final notices (notices of intention
to levy), as well as notices of deficiency, receipt of which
petitioner does not dispute. These numerous notices were
sufficient and met the requirements of section 6303(a). Hansen
v. United States, 7 F.3d 137, 138 (9th Cir. 1993); Hughes v.
United States, 953 F.2d 531, 536 (9th Cir. 1992); Weishan v.
Commissioner, T.C. Memo. 2002-88. “The form on which a notice of
assessment and demand for payment is made is irrelevant as long
as it provides the taxpayer with all the information required
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