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administrative procedure have been met. Id. Petitioner has not
shown any irregularity in respondent’s assessment procedure that
would raise a question about the validity of the assessments or
the information contained in Forms 4340 with respect to peti-
tioner’s taxable years 1997 and 1998. We hold that the assess-
ments with respect to petitioner’s taxable years 1997 and 1998
were valid and that the Appeals officer satisfied the verifica-
tion requirement of section 6330(c)(1). See id.4
Based upon our examination of the entire record before us,
we find that respondent did not abuse respondent’s discretion in
determining to proceed with the collection action as determined
4We shall not specifically address any additional matters,
such as the following, which petitioner asserts in his petition,
all of which, as indicated above, the Court finds to be frivolous
and/or groundless:
6) * * * But in any case, Petitioner
pointed out to the appeals officer, if
he would simply identify for Petitioner
the statute that established Peti-
tioner’s income tax “liability”; Peti-
tioner would pay the taxes and penalties
at issue without further adieu. * * *
7) Petitioner asked the appeals officer to
identify for Petitioner the statute that
required Petitioner “to pay” the income
taxes at issue. Even though the exis-
tence of such a statute was a “relevant
issue relating to the unpaid tax,” as
stated in 6330(c)(2)(A). Despite the law
specifically providing that this issue
could be raised (since it is obviously a
“relevant issue.” What could be more
relevant?) the appeals officer refused
to identify any such statute. * * *
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