Gregory L. Shireman - Page 8

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          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 any                






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