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this proceeding because they received notices of deficiency for
those years.3
2. Whether Respondent Is Required To Identify for
Petitioners Internal Revenue Code Sections Which Make
Them Liable for Federal Income Tax
Petitioners contend that respondent is required to tell them
which Internal Revenue Code sections make them liable for Federal
income tax. We disagree. Respondent is not required to identify
the Code sections which establish petitioners’ liability for tax,
additions to tax, or penalties. See Nestor v. Commissioner,
supra at 167.
3. Whether Respondent Issued a Valid Notice and Demand for
Payment for Each Year In Issue
Petitioners contend that respondent did not issue a valid
notice and demand for payment for each year in issue. We
disagree.
Section 6330(c)(1) does not require the Commissioner to use
any particular document to meet the notice and demand
requirement. Kaye v. Commissioner, T.C. Memo. 2003-74; Wagner v.
Commissioner, T.C. Memo. 2002-180; see also Roberts v.
Commissioner, 118 T.C. 365, 371 (2002). The form on which a
notice of assessment and demand for payment is made is irrelevant
3 Petitioners may not contend that they did not receive
self-employment income because they may not dispute the
underlying tax liability. Moreover, petitioners’ assertion that
no provision of the Internal Revenue Code makes them liable for
Federal income taxes is frivolous.
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