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Petitioner next argues that the Appeals officer was required
by section 6330(c)(1) to provide him with verification from the
Secretary that the requirements of any applicable law or
administrative procedures were met. Section 6330(c)(1) requires
the Appeals officer to “obtain” such verification, but it does
not require the Appeals officer to provide the verification to
the taxpayer. Nestor v. Commissioner, supra at 166; sec.
301.6330-1(e)(1), Proced. & Admin. Regs. As stated above, the
Appeals officer did review Form 4340 for petitioner’s 1998
account. This was sufficient to fulfill the requirement of
section 6330(c)(1). Nestor v. Commissioner, supra at 166.
Petitioner next contends that he did not receive a notice
and demand for payment for 1998 as required by section 6303(a).
However, the Form 4340 reviewed by the Appeals officer showed
that a notice of balance due was sent to petitioner on July 9,
2001, and that a notice of intent to levy was sent to petitioner
on January 18, 2002. Each of these notices fulfills the notice
and demand for payment requirement of section 6303(a).
Standifird v. Commissioner, T.C. Memo. 2002-245, affd. 72 Fed.
Appx. 729 (9th Cir. 2003); see also Tornichio v. Commissioner,
T.C. Memo. 2002-291.
C. Section 6673 Penalty
At trial, respondent orally moved that the Court impose a
penalty under section 6673. Section 6673(a)(1) authorizes this
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