-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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