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F.3d 137, 138 (9th Cir. 1993); United States v. Chila, 871 F.2d
1015, 1019 (11th Cir. 1989); Craig v. Commissioner, 119 T.C. 252,
261-262 (2002). Respondent also relies on the notice of intent
to levy issued in this case as satisfying section 6303(a). See
Hughes v. United States, 953 F.2d 531, 536 (9th Cir. 1992);
Standifird v. Commissioner, T.C. Memo. 2002-245, affd. 72 Fed.
Appx. 729 (9th Cir. 2003). In light of the Appeals officer’s
review of the transcripts of account, we are satisfied that he
obtained sufficient verification that the requirements of
applicable laws and procedures had been met.
Petitioner also advanced a claim at trial that the period of
limitations for collection of his 1992 liability had expired.
The period for collection following assessment is 10 years. Sec.
6502(a). If a hearing is requested under section 6330(a)(3)(B),
the running of the period of limitations for collection is
suspended for the period during which the hearing, and appeals
therein, are pending. Sec. 6330(e)(1); Boyd v. Commissioner, 117
T.C. 127, 130-131 (2001). Further, the period for collection
shall not expire before the 90th day after the day on which there
is a final determination in the hearing. Sec. 6330(e)(1).
Petitioner's 1992 liability was assessed on June 7, 1993, and
petitioner requested a hearing under section 6330(a)(3)(B) on May
1, 2001; i.e., within the 10-year period following the June 7,
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