- 8 - respondent would proceed against petitioner and that respondent could file a lien against or levy petitioner’s property, the examiner was giving petitioner notice that respondent was going to use the lawful means provided by statute to assess and collect the taxes. See Ballard v. Commissioner, supra; Price v. Commissioner, supra; Narragansett Wire Co. v. Commissioner, T.C. Memo. 1973-135, affd. 491 F.2d 371 (1st Cir. 1974). We agree with respondent and conclude that petitioner did not sign the Form 4549-CG under duress, coercion, fraud, or misrepresentation, and that petitioner’s waiver of restrictions on assessment is valid. Petitioner also argues that respondent erred by concluding that no notices of deficiency were required to be issued for 1996 and 1997. This argument has no merit. By signing Form 4549-CG, petitioner consented to the immediate assessment of the tax liability set forth therein plus any penalties and interest and agreed not to receive any notices of deficiency. Aguirre v. Commissioner, 117 T.C. 324, 327 (2001); see Perez v. Commissioner, T.C. Memo. 2002-274. Likewise, we reject petitioner’s argument that respondent erred by failing to verify that all applicable laws and administrative procedures were met. Under section 6330(c)(1), during a hearing, an Appeals officer is required to obtain verification from the Secretary that the requirements of anyPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011