-8- 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 thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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