-9-
respondent attempted to assess or collect a tax before this
Court’s decision became final, the remedy available to
petitioners would have been an injunction against collection or
refund of any tax so collected. See sec. 6213(a). A premature
assessment, if any occurred, would not taint this proposed levy,
which seeks to collect an assessment that was timely and validly
made.
C. Conclusion
We hold that: (1) The assessments were valid, see Kuglin v.
Commissioner, T.C. Memo. 2002-51; see also Duffield v.
Commissioner, T.C. Memo. 2002-53, (2) the Appeals officer
satisfied the verification requirement of section 6330(c)(1), see
Yacksyzn v. Commissioner, T.C. Memo. 2002-99, and (3) petitioners
have not demonstrated in this proceeding any irregularity in the
assessment procedure which would raise a question about the
validity of the assessment. See Mann v. Commissioner, T.C. Memo.
2002-48.
To reflect the foregoing,
An appropriate order and
decision will be entered for
respondent.
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