Clyde E. Hack and Carole J. Hack - Page 8




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          information.  Petitioners have not demonstrated in this                     
          proceeding any irregularity in the assessment procedure that                
          would raise a question about the validity of the assessment or              
          the information contained in the transcript of account.  See Mann           
          v. Commissioner, T.C. Memo. 2002-48.  We hold that the assessment           
          made by respondent is valid.  See Kuglin v. Commissioner, T.C.              
          Memo. 2002-51; see also Duffield v. Commissioner, T.C. Memo.                
          2002-53.                                                                    
               Petitioners next argue 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 Commissioner to rely upon a particular                 
          document (e.g., the summary record itself rather than transcripts           
          of account) to satisfy this verification requirement.  Kuglin v.            
          Commissioner, supra; see also Weishan v. Commissioner, T.C. Memo.           
          2002-88.  Petitioners received a transcript of their account, and           
          the Appeals officer reviewed the transcript at the hearing.  The            
          use of computer-generated transcripts of account is 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 v. Commissioner, T.C. Memo. 2002-204;             
          Howard v. Commissioner, T.C. Memo. 2002-81; Mann v. Commissioner,           
          supra.  We hold that the Appeals officer satisfied the                      






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