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this regard, we note that the transcripts of account on which the
Appeals officer relied in this case contained all the information
prescribed in section 301.6203-1, Proced. & Admin. Regs. Id.
Moreover, the Form 4340 substantiates the information contained
in the transcripts of account.
Petitioner has not alleged any irregularity in the
assessment procedure that would raise a question about the
validity of the assessments or the information contained in the
transcripts of account or the Form 4340. Id.; 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 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 February 16, 2001.
Finally, we mention section 6673(a)(1), which authorizes the
Tax Court to require a taxpayer to pay to the United States a
penalty not in excess of $25,000 whenever it appears that
proceedings have been instituted or maintained by the taxpayer
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