Robert R. Villwock - Page 14

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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            
               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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