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Petitioner has not alleged any irregularity in the
assessment procedure that would raise a question about the
validity of the assessment or the information contained in the
transcript. See Davis v. Commissioner, 115 T.C. 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 of his tax liability 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 which the Appeals officer relied
upon in issuing the notice of determination shows that respondent
sent petitioner a notice that he owed taxes for 1997 on the same
date that respondent made assessments against petitioner for the
tax and accuracy-related penalty determined in the notice of
deficiency. Such a notice constitutes a notice and demand for
payment within the meaning of section 6303(a). See, e.g., Hughes
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