Johnny Owings Milam, Jr. and Brenda Ramsey Milam - Page 7

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          issues raised at the administrative level and issues raised for             
          the first time in the petition.                                             
               A.  Notice of Deficiency                                               
               Petitioners’ first allegation of error is that the notice of           
          deficiency they received for 1996 and 1997 was invalid because it           
          was not issued in compliance with section 6065, which generally             
          provides that documents or statements required to be made under             
          the internal revenue laws must be subscribed under penalties of             
          perjury.  Petitioners’ argument is without merit.  The                      
          requirements of section 6065 are directed at documents                      
          originating with the taxpayer, not respondent.  Davis v.                    
          Commissioner, 115 T.C. 35, 42 (2000).  Therefore, respondent’s              
          failure to sign the notice of deficiency under penalties of                 
          perjury does not invalidate it.                                             
               B.  Verification Requirement                                           
               Petitioners also allege that the Appeals officer failed to             
          satisfy the requirements of section 6330(c)(1), which provides              
          that the Appeals officer must verify that any applicable law or             
          administrative procedure has been met.  While the Notice of                 
          Determination contains only a general, conclusory statement to              
          the effect that the applicable laws and administrative                      
          requirements were met, we have examined certified copies of Forms           
          4340 covering petitioners’ 1996 and 1997 taxable years, and on              
          that basis we are satisfied that petitioners’ liabilities for               






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