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copy of pertinent parts of the record of assessment setting forth
the taxpayer’s name, the date of assessment, the character of the
liability assessed, the taxable period, if applicable, and the
amounts assessed. Sec. 6203; sec. 301.6203-1, Proced. & Admin.
Regs. A taxpayer receiving a copy of Form 4340 has been provided
with all the documentation to which he or she is entitled under
section 6203 and section 301.6203-1, Proced. & Admin. Regs.
Roberts v. Commissioner, supra at 370 n.7. This Court likewise
has upheld collection action where taxpayers were provided with
literal transcripts of account (so-called MFTRAX). See, e.g.,
Frank v. Commissioner, T.C. Memo. 2003-88; Swann v. Commissioner,
T.C. Memo. 2003-70. The January 29, 2003, letter to petitioner
from the settlement officer enclosed copies of Forms 4340 for
each year.
Petitioner has also denied receiving the “Notices of
Assessment”, presumably alluding to the notice and demand for
payment that section 6303(a) establishes should be given within
60 days of the making of an assessment. However, a notice of
balance due constitutes a notice and demand for payment within
the meaning of section 6303(a). Craig v. Commissioner, supra at
262-263. The Forms 4340 indicate that petitioner was sent
notices of balance due for the tax years involved, and petitioner
has never denied receiving these notices.
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