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question about the validity of the assessments or the information
contained in the Forms 4340. See Davis v. Commissioner, 115 T.C.
35, 41 (2000); Mann v. Commissioner, T.C. Memo. 2002-48.
Petitioner’s testimony, the notices of deficiency, the
certified mail receipts, and the certified mail list establish
that respondent mailed the notices of deficiency via certified
mail to petitioner at his correct address. The Forms 4340
establish a proper assessment and that respondent sent petitioner
notice and demand for payment and notice of intent to levy. A
certified mail return receipt for the hearing notice and the fact
that petitioner attached the hearing notice to his hearing
request establish that petitioner received the hearing notice.
Accordingly, we hold that the Appeals officer satisfied the
verification requirement of section 6330(c)(1). Cf. Nicklaus v.
Commissioner, 117 T.C. 117, 120-121 (2001).
Petitioner has failed to raise a spousal defense, make a
valid challenge to the appropriateness of respondent’s intended
collection action, or offer alternative means of collection.
These issues are now deemed conceded. See Rule 331(b)(4).
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Last modified: May 25, 2011