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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. Roberts v. Commissioner, 118 T.C. 365, 371 n.10
(2002); Weishan v. Commissioner, T.C. Memo. 2002-88; Lindsey v.
Commissioner, T.C. Memo. 2002-87; Tolotti v. Commissioner, supra;
Duffield v. Commissioner, T.C. Memo. 2002-53; Kuglin v.
Commissioner, T.C. Memo. 2002-51. In this regard, we observe
that the computerized transcripts of account 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.
Commissioner, supra; Duffield v. Commissioner, supra; Kuglin v.
Commissioner, supra.6
6 To the extent that petitioner may still be arguing that
the Appeals officer failed to provide him with a copy of the
verification, we note that sec. 6330(c)(1) does not require that
the Appeals officer provide the taxpayer with a copy of the
verification at the administrative hearing. Nestor v.
Commissioner, 118 T.C. 162, 166 (2002). In any event, the
Appeals officer provided petitioner with copies of literal
transcripts of account for the taxable years 1997 and 1998.
Indeed, petitioner attached copies of these transcripts as
exhibits to his petition. Moreover, respondent’s counsel
provided petitioner with copies of Forms 4340 for the taxable
years 1997 and 1998, and petitioner attached copies of these
(continued...)
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