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as long as it gives the taxpayer the information required under
section 6303. Hughes v. United States, 953 F.2d 531, 536 (9th
Cir. 1992).
Respondent is required to show that the notices and demand
were sent to petitioners’ last known address, not that
petitioners received them. United States v. Chila, 871 F.2d
1015, 1019 (11th Cir. 1989); Pursifull v. United States, 849
F.Supp. 597, 601 (S.D. Ohio 1993), affd. 19 F.3d 19 (6th Cir.
1994); Kaye v. Commissioner, supra. Respondent may rely on Form
4340 to show that notice and demand was mailed to petitioners.
Hansen v. United States, 7 F.3d 137, 138 (9th Cir. 1993); United
States v. Chila, supra.
The record includes a notice and demand for each year in
issue. The Forms 4340 show that respondent sent to petitioners
notices of balance due for the tax years involved, and
petitioners do not deny receiving these notices. A notice of
balance due constitutes a notice and demand for payment under
section 6303(a). Craig v. Commissioner, 119 T.C. 252, 262-263
(2002).
4. Whether Respondent Is Required To Provide to
Petitioners Documents From the Secretary Verifying That
All Legal and Procedural Requirements Were Met
Petitioners contend that respondent is required to give them
documents from the Secretary verifying that all legal and
procedural requirements were met. We disagree.
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