-8-
petitioners argue that the Appeals officer failed to obtain
verification from the Secretary that the requirements of all
applicable laws and administrative procedures were met as
required by section 6330(c)(1). We disagree with this argument.
Section 6330(c)(1) does not require the Appeals officer to rely
upon a particular document (e.g., the summary record itself
rather than transcripts of account) in order to satisfy this
verification requirement. Kuglin v. Commissioner, T.C. Memo.
2002-51; see also Weishan v. Commissioner, T.C. Memo. 2002-88.
Nor does it mandate that the Appeals officer actually give a
taxpayer a copy of the verification upon which the Appeals
officer relied. Sec. 6330(c)(1); sec. 301.6330-1(e)(1), Proced.
& Admin. Regs.; see also Nestor v. Commissioner, 118 T.C. 162
(2002). Given the additional fact that petitioners were actually
given copies of the relevant Forms 4340, which are a valid
verification that the requirements of any applicable law or
administrative procedure have been met, Roberts v. Commissioner,
118 T.C. 365 (2002); Mudd v. Commissioner, T.C. Memo. 2002-204;
Howard v. Commissioner, T.C. Memo. 2002-81; Mann v. Commissioner,
T.C. Memo. 2002-48, we hold that: (1) The assessments were
valid, Kuglin v. Commissioner, supra; see also Duffield v.
Commissioner, T.C. Memo. 2002-53, and (2) the Appeals officer
3(...continued)
Appeals officer’s determination. Those issues are frivolous.
Moreover, they are not properly before the Court for decision.
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