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support collection action under section 6330. Id. at 40-41. Nor
is the Commissioner required to use Form 23C in making an
assessment. Roberts v. Commissioner, 118 T.C. 365, 369-371
(2002), affd. 329 F.3d 1224 (11th Cir. 2003). Furthermore, a
taxpayer receiving a copy of Form 4340 has been provided with all
the documentation to which he or she is entitled under section
6203 and section 301.6203-1, Proced. & Admin. Regs. Roberts v.
Commissioner, supra at 370 n.7.
Here, petitioner has cited no irregularities that would cast
doubt on the information recorded in the Form 4340, and he was
furnished with copies of this document both prior to and at the
hearing. Additionally, arguments substantially identical to his
statements concerning “filed returns” have been summarily
rejected. See, e.g., Fink v. Commissioner, T.C. Memo. 2003-61.
We conclude that petitioner’s complaints regarding the assessment
are meritless.
Petitioner also alleges not to have received the notice and
demand for payment that section 6303(a) establishes should be
given within 60 days of the making of an assessment. However, a
notice of balance due constitutes a notice and demand for payment
within the meaning of section 6303(a). Craig v. Commissioner,
119 T.C. 252, 262-263 (2002). The Form 4340 indicates that
petitioner was sent at least two such notices of balance due, on
April 17 and May 22, 2000.
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