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We likewise reject petitioners’ assertion that the Appeals
officer failed to verify that all applicable laws and procedures
were complied with as required under section 6330(c)(1). First,
the record shows that the letter that respondent issued to
petitioners dated December 27, 1999, served as a notice and
demand for payment. In particular, the letter informed
petitioners that changes had been made to their account for 1997
and requested that they pay the amount due by January 17, 2000.
The issuance of this letter corresponded with the date of
assessment of tax, penalties, and interest as reflected in the
transcript of account that respondent provided to petitioners
before the Appeals Office hearing. We hold that the letter
constituted a 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).
We also reject petitioners’ assertion that the Appeals
officer’s reliance on a transcript of account was insufficient
verification from the Secretary that the requirements of all
applicable laws and administrative procedures were met as
required under section 6330(c)(1). Petitioners assert that they
are entitled to a copy of a record of assessment.
Federal tax assessments are formally recorded on a summary
record of assessment. Sec. 6203. The summary record of
assessment must “provide identification of the taxpayer, the
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