Jeffrey S. and Susan L. Duffield - Page 4

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          liability only if petitioners did not receive a notice of                   
          deficiency or have an opportunity to dispute the liability.                 
          Section 6330(d) provides for Tax Court review of the                        
          Commissioner’s determination.                                               
               Petitioners do not contest the underlying liabilities but              
          contend that section 6330(c)(1) requires the production of Form             
          23C.  Respondent contends that the Appeals officer did not abuse            
          her discretion by relying on the transcripts to verify the                  
          assessments.  We agree with respondent.  The transcripts                    
          contained the requisite information (i.e., “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).  Kuglin v. Commissioner, T.C.           
          Memo. 2002-51.                                                              
               Where the Commissioner provides the taxpayer with Forms 4340           
          (i.e., proof of assessment) after the hearing and before trial,             
          and the taxpayer does not “show at trial any irregularity in the            
          assessment procedure that would raise a question about the                  
          validity of the assessments”, the taxpayer is not prejudiced.               
          Nestor v. Commissioner, 118 T.C. ___, ___ (2002) (slip op. at 9).           
          At trial, petitioners did not show any irregularity in the                  
          assessment procedure.  Accordingly, we sustain the respondent’s             

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