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might suggest that these arguments have some colorable merit.”
Crain v. Commissioner, 737 F.2d 1417, 1417 (5th Cir. 1984).
Petitioner next contends 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 under section 6330(c)(1). We reject petitioner’s
argument inasmuch as the record shows that the Appeals officer
obtained, reviewed and provided petitioner with copies of Forms
4340 with regard to petitioner’s account for 1995 and 1996.
Federal tax assessments are formally recorded on a record of
assessment. Sec. 6203. The summary record of assessment,
through supporting records, must “provide identification of the
taxpayer, the character of the liability assessed, the taxable
period, if applicable, and the amount of the assessment.” Sec.
301.6203-1, Proced. & Admin. Regs. We have held that Forms 4340
are presumptive evidence on which an Appeals officer may rely to
verify that an assessment was made against a person for purposes
of sections 6320 and 6330. Davis v. Commissioner, 115 T.C. 35,
40-41 (2000); see Nestor v. Commissioner, 118 T.C. 162, 166-167
(2002).
Petitioner has not demonstrated any irregularity in the
assessment procedure that would raise a question about the
validity of the assessments or the information contained in the
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