Michael Craig v. Commissioner - Page 17




                                        -17-                                          
          We turn to address these allegations.                                       
               First, petitioner alleges 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.  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 petitioner was actually given copies of the            
          relevant Forms 4340,6 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           



               6 Federal tax assessments are formally recorded on a record            
          of assessment.  Sec. 6203.  The summary record of assessment 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.  The record shows that in addition to Forms 4340,                     
          petitioner received IMF MCC transcripts of account for 1990,                
          1991, 1992, and 1995.  Those transcripts of petitioner’s account            
          for respective years also contained all the information required            
          under section 301.6203-1, Proced. & Admin. Regs.                            





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