- 24 -
determination concluded that the computerized transcripts of
petitioner's account showed that notice and demand for each
liability had been sent on the date it was assessed. Although
this issue is not specifically addressed in the 2004 supplemental
determination, Settlement Officer Waters's case notes state that
records from respondent's IDRS (integrated data retrieval system)
confirm that "notice and demand [were] made on all years".
We are persuaded that notice and demand pursuant to section
6303 was given to petitioner and that Settlement Officer Waters
properly so verified.9 Petitioner's claims regarding notice and
demand are meritless.
Collection Alternatives
In the absentee letter, petitioner raised questions
concerning collection alternatives. The 2004 supplemental
determination did not consider collection alternatives on the
grounds, inter alia, that petitioner had not responded to
Appeals' request that he submit a collection information
statement. The record establishes that Appeals requested
collection information statements from petitioner on at least two
occasions, and we are satisfied that petitioner ignored these
requests. Thus, it was not an abuse of discretion for the
9 The notice of intent to levy in this case would in any
event likely satisfy the requirements of sec. 6303. See Hughes
v. United States, 953 F.2d 531, 536 (9th Cir. 1992); Perez v.
Commissioner, T.C. Memo. 2002-274; Standifird v. Commissioner,
T.C. Memo. 2002-245, affd. 72 Fed. Appx. 729 (9th Cir. 2003).
Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 NextLast modified: May 25, 2011