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notice and demand for payment under section 6303(a). Craig v.
Commissioner, 119 T.C. 252, 262-263 (2002). Respondent is not
required to use Form 17 as the notice and demand for payment.
E.g., Keene v. Commissioner, T.C. Memo. 2002-277; Tapio v.
Commissioner, T.C. Memo. 2002-141.
As a further illustration of the frivolous and/or groundless
nature of petitioner’s position in this case, petitioner contends
in petitioner’s response that the settlement officer failed to
obtain verification that the requirements of any applicable law
or administrative procedure have been met, as required by section
6330(c)(1). In this regard, petitioner contends that the settle-
ment officer improperly relied on Form 4340 to meet the verifica-
tion requirement of section 6330(c)(1).
The record establishes that the settlement 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. As for the
settlement officer’s reliance on Form 4340, at the Appeals Office
hearing, the settlement officer relied on, and gave petitioner,
Form 4340 with respect to petitioner’s taxable year 1998.
Section 6330(c)(1) does not require the settlement officer to
rely on a particular document to satisfy the verification re-
quirement imposed by that section. Craig v. Commissioner, supra
at 261-262. Nor does section 6330(c)(1) require the settlement
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