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and demand for payment 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. NOTICE AND DEMAND FOR TAX.
(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 record shows that respondent sent petitioners a notice of
change to their account on the same date that respondent made
assessments against petitioners for the tax and accuracy-related
penalty determined in the notice of deficiency, as well as two
subsequent collection notices. We hold that these notices
constituted notice and demand for payment within the meaning of
section 6303(a). 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).
Petitioners have 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 September 21, 2001.
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