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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 tax
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