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Petitioner next argues that his hearing was invalid and
collection may not proceed because the Appeals officer refused to
provide him with verification, and did not verify at the hearing,
that the requirements of any applicable law or administrative
procedure were met, as required under section 6330(c)(1).
Petitioner admitted in his petition and at trial that, at the
hearing, the Appeals officer would not allow petitioner to see
the Appeals officer’s copies of the transcripts of account. On
the basis of the foregoing, we are satisfied that the Appeals
officer obtained verification at the hearing; he was not required
to provide any such verification to petitioner. See Nestor v.
Commissioner, 118 T.C. 162, 166-167 (2002).
Petitioner next claims that he did not receive notice and
demand for payment (as required by section 6303(a)) with respect
to the liabilities for any of the taxable years in question, and
that the Appeals officer did not consider his contentions in this
regard. Petitioner’s claim of nonreceipt is belied by the
certified copies of Forms 4340, Certificate of Assessments,
Payments and Other Specified Matters, in evidence for each year,
which show that statutory notices of balance due were issued for
each year. Absent some showing of irregularity in the Forms
4340, which petitioner has not made, those records serve as
presumptive evidence that notice and demand pursuant to section
6303(a) was mailed to petitioner. See Hansen v. United States, 7
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