-13-
Petitioner argues that because the notice of deficiency was
not sent with a return receipt requested respondent’s mailing
thereof was inadequate. Section 6212(a), however, does not
require mailing of notices of deficiency with a return receipt
requested. Eisenberg v. Commissioner, T.C. Memo. 1983-767, affd.
without published opinion 753 F.2d 1078 (7th Cir. 1985).
Petitioner cites Brafman v. United States, 384 F.2d 863, 865
(5th Cir. 1967), and petitioner argues that because respondent’s
transcript of account was not signed by a proper official the tax
assessments against petitioner are invalid and the proposed levy
action is not appropriate. We disagree. Forms 4340 are not
required to be signed. Nestor v. Commissioner, 118 T.C. 162
(2002); Nicklaus v. Commissioner, 117 T.C. 117, 121 (2001);
sec. 301.6203-1, Proced. & Admin. Regs. The Forms 4340
reflecting petitioner's income tax liabilities for the years in
issue indicate that those tax liabilities were assessed and
remain largely unpaid.
Petitioner has not demonstrated any credible irregularity in
the assessment procedures that would raise a question about the
validity of the assessments.
Respondent’s Appeals officer verified that the assessments
of tax were proper and obtained verification that the
requirements of applicable laws and administrative procedures
were met.
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