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respondent sent petitioner a notice of balance due on January 8,
2001, the same day on which respondent assessed petitioner’s tax,
as well as any penalties and interest as provided by law, for
each of those years. A notice of balance due constitutes the
notice and demand for payment under section 6303(a). Craig v.
Commissioner, 119 T.C. 252, 262-263 (2002).
As a further illustration of the frivolous and/or groundless
nature of petitioner’s position in this case, petitioner contends
in the petition that the Appeals officer failed to obtain and to
produce verification that the requirements of any applicable law
or administrative procedure have been met, as required by section
6330(c)(1). The record establishes that the Appeals officer
obtained verification from the Secretary that the requirements of
any applicable law or administrative procedure were met, and we
reject petitioner’s contention to the contrary. At the Appeals
Office hearing, the Appeals officer relied on Forms 4340 with
respect to petitioner’s taxable years 1997 and 1998. Section
6330(c)(1) does not require the Appeals officer to rely on a
particular document to satisfy the verification requirement
imposed by that section. Craig v. Commissioner, supra at 261-
262. Nor does section 6330(c)(1) require the Appeals officer to
provide petitioner with a copy of the verification upon which the
Appeals officer relied. Id. at 262. Form 4340 is a valid
verification that the requirements of any applicable law or
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