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of his underlying tax liabilities for 1993 to 1997 in this
proceeding. See sec. 6330(c)(2)(B).
In addition, contrary to petitioner’s position, the Forms
4340 offered into evidence at trial show that respondent (1)
properly assessed the tax liabilities that respondent intends to
collect from petitioner, and (2) properly notified petitioner of
those assessments by way of notices of balance due. See, e.g.,
Hughes v. United States, 953 F.2d 531, 535-536 (9th Cir. 1992).
Numerous cases establish that no particular form of
verification of an assessment is required, that no particular
document need be provided to a taxpayer at an administrative
hearing conducted under section 6330, and that a Form 4340 (such
as that included in this record) and other transcripts of account
satisfy the verification requirements of section 6330(c)(1). See
Roberts v. Commissioner, 118 T.C. 365, 371 n.10 (2002), affd. 329
F.3d 1224 (11th Cir. 2003); Nestor v. Commissioner, 118 T.C. 162,
166 (2002); Lunsford v. Commissioner, 117 T.C. 183 (2001).
Petitioner has not alleged any irregularity in the
assessment procedure that would raise a question about the
validity of the assessments or the information contained in the
Forms 4340. Moreover, petitioner has failed to raise a spousal
defense, make a valid challenge to the appropriateness of
respondent's intended collection action, or offer alternative
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