- 13 -
liabilities for 1983 and 1993 to 1995 in this proceeding.8 See
Goza v. Commissioner, supra at 180-181.
Petitioner's conduct in his earlier deficiency cases at
docket Nos. 27411-88, 20474-90, 18627-97, and 6546-00, coupled
with his actions in this proceeding, clearly demonstrates that
petitioner exploited the collection review procedures primarily
for the purpose of delay. As discussed below, petitioner’s
arguments have absolutely no merit.9
Petitioner contends that the Appeals Office failed to verify
that all applicable laws and administrative procedures were met.
However, the Forms 4340 attached to respondent’s Motion for
Summary Judgment 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
8 The Court further notes that res judicata would appear to
provide an alternative basis for our holding on this point.
9 Under the circumstances, petitioner has given us no
reason to believe that remanding this matter to respondent's
Appeals Office would be productive or otherwise advance the
policies underlying sec. 6330. Consistent with our reasoning in
Keene v. Commissioner, 121 T.C. 8, 19-20 (2003), and in Kemper v.
Commissioner, T.C. Memo. 2003-195, we conclude that a remand is
unwarranted.
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