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3. Whether Respondent Issued a Notice and Demand for
Payment of Petitioner’s Tax for 1998, 2001, and 2002
Petitioner contends that respondent did not issue the notice
and demand for payment that section 6303(a) requires to be issued
within 60 days of assessment. We disagree. The notices of
demand for payment and of intent to levy that respondent sent to
petitioner fulfill the notice and demand for payment requirement
of section 6303(a). See Henderson v. Commissioner, T.C. Memo.
2004-157; Tornichio v. Commissioner, T.C. Memo. 2002-291;
Standifird v. Commissioner, T.C. Memo. 2002-245, affd. 72 Fed.
Appx. 729 (9th Cir. 2003). Respondent assessed tax for
petitioner and issued a notice and demand for payment to
petitioner as follows:
Year Assessment Notice and Demand
1998 Nov. 27, 2000 Dec. 18, 2000
2001 Apr. 8, 2002 May 13, 2002
2002 Sep. 22, 2003 Oct. 13, 2003
4. Whether Respondent Verified That Requirements of
Applicable Law and Administrative Procedures Had Been
Met and That Respondent’s Employees Had Authority From
the Secretary To Collect Tax
The Appeals officer must obtain verification that respondent
met requirements of applicable law and administrative procedures
before issuing the determination. Sec. 301.6320-1(e)(1), Proced.
& Admin. Regs. Internal revenue laws and regulations do not
require the Appeals officer to give the taxpayer a copy of the
delegation of authority from the Secretary to the person (other
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