- 12 -
Kuglin v. Commissioner, T.C. Memo. 2002-51. In this regard, we
observe that the Forms 4340 on which the Appeals officers relied
contained all the information prescribed in section 301.6203-1,
Proced. & Admin. Regs. See Weishan v. Commissioner, supra;
Lindsey v. Commissioner, supra; Tolotti v. Commissioner, supra;
Duffield v. Commissioner, supra; Kuglin v. Commissioner, supra.
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
Forms 4340. See Davis v. Commissioner, supra at 41; Mann v.
Commissioner, T.C. Memo. 2002-48. Accordingly, we hold that the
Appeals officers 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 valid
notice and demand for payment of the taxes in question. 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 Forms 4340 that the Appeals officers relied on during the
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011