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procedure have been met. However, section 6330(c)(1) does not
specify which documents the Commissioner must use to meet the
verification requirement. See, e.g., Kuglin v. Commissioner,
T.C. Memo. 2002-51. It was not an abuse of discretion for
respondent not to give petitioner the Forms 23C that he had
requested. See Hughes v. United States, 953 F.2d 531, 535-536
(9th Cir. 1992); Roberts v. Commissioner, 118 T.C. 365, 371
(2002), affd. 329 F.3d 1224 (11th Cir. 2003); Nestor v.
Commissioner, 118 T.C. 162, 166 (2002).
2. Whether Respondent Properly Assessed Petitioner’s Tax
for 1998, 2001, and 2002
Petitioner contends that respondent did not properly assess
petitioner’s tax for 1998, 2001, and 2002 because he did not
receive copies of Form 23C. We disagree. Respondent makes an
assessment of Federal tax on a record of assessment. Sec. 6203.
The Commissioner is not required to use Form 23C in making an
assessment. Roberts v. Commissioner, supra at 369-371. The
record of assessment must identify the taxpayer, the taxable
period, and the character and amount of the liability assessed.
Sec. 301.6203-1, Proced. & Admin. Regs. Skidmore reviewed
transcripts that appeared to him to show that petitioner’s tax
for 1998, 2001, and 2002 had been validly assessed. Petitioner
has not shown that there was any irregularity in the assessment
procedure. We hold that the assessments are valid.
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