Homer W. and Nancy L. Winans - Page 9

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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                   
               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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