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questions whether respondent used the particular form that
petitioner argues must be used for the notice and demand to be
valid. In that regard, 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). In addition, it has been held that “‘[t]he 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)); Planned Invs.,
Inc. v. United States, 881 F.2d 340, 344 (6th Cir. 1989).
In addition, respondent is not required to prove receipt by
petitioner of notice and demand, but need only show that the
notices and demand were sent to petitioner’s last known address.
United States v. Chila, 871 F.2d 1015, 1019 (11th Cir. 1989);
Pursifull v. United States, 849 F. Supp. 597, 601 (S.D. Ohio
1993), affd. 19 F.3d 19 (6th Cir. 1994).
Finally, Form 4340 may be relied upon to show that notice
and demand was mailed to a taxpayer. Hansen v. United States, 7
F.3d 137, 138 (9th Cir. 1993); United States v. Chila, supra.
Respondent’s failure to produce a copy of the notice and demand
document is not conclusive, “because the notices are computer
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