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Certificate of Assessments, Payments and Other Specified Matters,
pertaining to his account for the taxable year 1998. At the
hearing, petitioner did not contradict the Appeals officer’s
assertion that petitioner had received the notice of deficiency
(see supra “B”). However, petitioner did allege that he never
received “a statutory notice and demand for payment” (emphasis in
the original), and he requested a copy of the “summary record of
assessment”. Petitioner also requested that the Appeals officer
provide verification that all applicable laws and administrative
procedures had been followed in the assessment and collection
process; in this regard, petitioner was informed by the Appeals
officer that the transcript provided (i.e., Form 4340) was
sufficient to satisfy the verification requirement of section
6330(c)(1). In addition, petitioner stated that he was
challenging the underlying liability. Finally, in response to
the Appeals officer’s question whether petitioner wished to
discuss collection alternatives, petitioner stated that “I’m
prepared to pay * * * if you can convince me * * * where my
liability is.”
In a letter dated April 22, 2002, that was sent immediately
after the administrative hearing, the Appeals officer mailed
petitioner copies of relevant statutes and court cases, including
Davis v. Commissioner, T.C. Memo. 2001-87, in which this Court
imposed on the taxpayer a $4,000 penalty pursuant to section
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Last modified: May 25, 2011