Shade D. Coleman III and Maria M. Coleman - Page 8

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               We likewise reject petitioners’ argument 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).  The record shows               
          that the Appeals officer obtained, reviewed, and provided to                
          petitioners a copy of, a transcript of account (Form 4340) with             
          regard to petitioners’ taxable year 1997.                                   
               Federal tax assessments are formally recorded on a record of           
          assessment.  Sec. 6203.  “The summary record, through supporting            
          records, shall 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.                                                      
               Section 6330(c)(1) does not require the Commissioner to rely           
          on a particular document to satisfy the verification requirement            
          imposed therein.  Weishan v. Commissioner, T.C. Memo. 2002-88;              
          Lindsey v. Commissioner, T.C. Memo. 2002-87; Tolotti v.                     
          Commissioner, T.C. Memo. 2002-86; Duffield v. Commissioner, T.C.            
          Memo. 2002-53; Kuglin v. Commissioner, T.C. Memo. 2002-51.  In              
          this regard, we observe that the Form 4340 on which the Appeals             
          officer relied contained all the information prescribed in                  
          section 301.6203-1, Proced. & Admin. Regs.  See Weishan v.                  
          Commissioner, supra; Lindsey v. Commissioner, supra; Tolotti v.             

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