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that a valid assessment was made. See Nestor v. Commissioner,
118 T.C. 162, 166 (2002); Schaper v. Commissioner, T.C. Memo.
2002-203; Schroeder v. Commissioner, T.C. Memo. 2002-190. Absent
a showing of irregularity, a Form 4340 is sufficient to establish
that a valid assessment was made. See Nestor v. Commissioner,
supra at 167; Davis v. Commissioner, 115 T.C. 35, 40-41 (2000);
Yazzie v. Commissioner, T.C. Memo. 2004-233. In the present
case, the Forms 4340 for 1996, 1997, and 1998 identify
petitioner, the type of liability assessed, the taxable period,
and the amount of the assessment. Because petitioner does not
identify any irregularities in the assessment procedure used to
assess the 1996, 1997, and 1998 liabilities, we must conclude
that valid assessments for those years were made.
Petitioner also argues that respondent failed to issue
notice and demand for payment with respect to the 1996-98
liabilities. The Appeals officer may rely on Form 4340 to verify
that a notice and demand for payment was sent to the taxpayer.
See Schaper v. Commissioner, supra; Schroeder v. Commissioner,
supra. In this case, the Forms 4340 for 1996, 1997, and 1998
show that respondent issued to petitioner notices of balance due
for each of the unpaid tax liabilities.7 Petitioner has failed to
7 Notices of balance due constitute notice and demand for
payment within the meaning of sec. 6303(a). See Thompson v.
Commissioner, T.C. Memo. 2004-204; Henderson v. Commissioner,
T.C. Memo. 2004-157; Standifird v. Commissioner, T.C. Memo. 2002-
(continued...)
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