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taken or performed. In effect, he questions the authenticity of
the documents used by respondent to meet the statutory
requirements. Section 6330(c)(1) does not require the
Commissioner to rely on a particular document to satisfy the
verification requirement. Wagner v. Commissioner, T.C. Memo.
2002-180; see also Roberts v. Commissioner, 118 T.C. 365, 371
(2002), affd. 329 F.3d 1224 (11th Cir. 2003). In addition, it
has been held that “‘The form on which a notice of assessment and
demand for payment is made is irrelevant as long as it provides
the taxpayer with all the information required under * * *
[section 6303].’” Hughes v. United States, 953 F.2d 531, 536
(9th Cir. 1992) (quoting Elias v. Connett, 908 F.2d 521, 525 (9th
Cir. 1990)). Accordingly, we find petitioner’s arguments to be
specious and without merit.
At the administrative hearing, petitioner was provided with
documents that satisfied respondent’s verification requirement.
From the transcript of the hearing, it is also clear that
petitioner did not raise any issue provided for in section
6330(c)(2). To the extent that petitioner made arguments, they
were spurious and without merit. Lunsford v. Commissioner, 117
T.C. 183 (2001); Davis v. Commissioner, supra.
Accordingly, we hold that respondent has not abused his
discretion in determining to proceed with collection as set forth
in the February 5, 2001, Final Notice--Notice of Intent to Levy
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