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taxpayer, nevertheless, this “notice” does not satisfy the
requirements of � 6303(a) * * *.[4]
If only to ensure that computer-assisted legal research
databases place a “negative treatment indicated” flag on this
excerpt, we stress again that this Court rejects the notion that
magic words are required to make a sufficient “demand” on a
taxpayer who owes taxes. We have repeatedly held that the Code’s
requirement of “notice and demand” in such sections as 6303(a)
and 6331(a) is met when the Commissioner informs a taxpayer “of
the amount owed and [requests] payment.” See, e.g., Koenig v.
Commissioner, T.C. Memo. 2003-40; Schaper v. Commissioner, T.C.
Memo. 2002-203; Weishan v. Commissioner, T.C. Memo. 2002-88. We
have also specifically held that notices of balance due--
precisely the sort of notices respondent sent to petitioner--
“[constitute] a notice and demand for payment under section
6303(a).” Craig v. Commissioner, 119 T.C. 252, 262-263 (2002);
Koenig v. Commissioner, supra.
Respondent’s decision to proceed with collection was no
abuse of discretion. There being no other issues to be decided,
4 As petitioner is careful to point out, this was dictum--
the court in Toussiant found an adequate “demand” in other timely
notices that the IRS had sent to the taxpayer. Toussiant v.
Dept. of the Treasury, No. 91-3150, slip op. at 8-9 (D.N.J. Aug.
2, 1991).
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