- 9 - makes him “liable” for income taxes or requires him “to pay” income taxes. We have consistently rejected this type of frivolous, tax-protester argument, and we perceive no reason, nor are we required, to address such contentions. See, e.g., Crain v. Commissioner, 737 F.2d 1417 (5th Cir. 1984); Keene v. Commissioner, T.C. Memo. 2002-277; Hall v. Commissioner, T.C. Memo. 2002-267. We address petitioner’s remaining contentions to determine whether the Appeals officer abused his discretion. See Nicklaus v. Commissioner, 117 T.C. 117, 120 (2001). Section 6330(c)(1) requires the Appeals officer to verify that the requirements of any applicable law or administrative procedure have been met. However, section 6330(c)(1) does not require the Appeals officer to rely on a particular document to satisfy his verification function. Kuglin v. Commissioner, T.C. Memo. 2002-51. Further, that section does not require the Appeals officer to provide a copy of the verification that the requirements of any applicable law or administrative procedure have been met. Nestor v. Commissioner, 118 T.C. 162, 166 (2002). In the instant case, the Appeals officer reviewed transcripts of petitioner’s account for 1994, 1997, 1998, and 1999, as well as other relevant items in the case file. The Appeals officer verified that all applicable laws and administrative procedures had been met and that petitioner received notice and demand for payment for the unpaid taxPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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