Larry R. Johnston - Page 15

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          6330(c)(1) mandates neither that the Appeals officer rely on a              
          particular document in satisfying the verification requirement              
          nor that the Appeals officer actually give the taxpayer a copy of           
          the verification upon which he or she relied.  Craig v.                     
          Commissioner, 119 T.C. 252, 262 (2002); Nestor v. Commissioner,             
          118 T.C. at 166.                                                            
               A Form 4340, for instance, constitutes presumptive evidence            
          that a tax has been validly assessed pursuant to section 6203.              
          Davis v. Commissioner, 115 T.C. at 40 (and cases cited thereat).            
          Consequently, absent a showing by the taxpayer of some                      
          irregularity in the assessment procedure that would raise a                 
          question about the validity of the assessments, a Form 4340                 
          reflecting that tax liabilities were assessed and remain unpaid             
          is sufficient to support collection action under section 6330.              
          Id. at 40-41.  We have specifically held that it is not an abuse            
          of discretion for an Appeals officer to rely on Form 4340, Nestor           
          v. Commissioner, supra at 166; Davis v. Commissioner, supra at              
          41, or a computer transcript of account, Schroeder v.                       
          Commissioner, T.C. Memo. 2002-190; Mann v. Commissioner, T.C.               
          Memo. 2002-48, to comply with section 6330(c)(1).                           
               Here, the record contains Forms 4340 for 1993, 1994, 1995,             
          1996, and 1997, indicating that assessments were made for the               
          year and that taxes remain unpaid.  Petitioner has cited no                 








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