Randal W. Howard - Page 13

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          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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