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required by section 6330(c)(1) where the Appeals officer obtained
and reviewed a so-called TXMODA computer-generated transcript to
verify that assessments were properly made and that notice and
demand for payment had been issued to the taxpayer on the date of
assessment. See, e.g., Harp v. Commissioner, T.C. Memo. 2007-83;
Kubon v. Commissioner, T.C. Memo. 2005-71; Tornichio v.
Commissioner, T.C. Memo. 2002-291; Schroeder v. Commissioner,
T.C. Memo. 2002-190; Weishan v. Commissioner, T.C. Memo. 2002-88,
affd. 66 Fed. Appx. 113 (9th Cir. 2003).
Petitioner does not dispute that the Appeals settlement
officer reviewed a TXMODA computer transcript to verify that the
assessments for petitioner’s 2003 taxes were properly made and
that notice and demand for payment was issued to petitioner on
the date of assessment. Petitioner has not alleged, and the
record does not suggest, any irregularity in the assessment
procedure. We conclude that the Appeals settlement officer
properly verified that the requirements of applicable laws and
administrative procedures had been met, as required by section
6330(c)(1).
In his objection to respondent’s motion for summary
judgment, petitioner acknowledges that he “did not challenge the
underlying liability at the time of the petition”. Petitioner
now urges, however, that his underlying liability for a tax
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