-8-
contained in the transcripts 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 the Form 4340. The use of this
form is a valid verification that the requirements of any
applicable law or administrative procedure have been met. E.g.,
Roberts v. Commissioner, 118 T.C. 365 (2002). We hold that the
Appeals officer satisfied the verification requirement of section
6330(c)(1). Yacksyzn v. Commissioner, T.C. Memo. 2002-99; cf.
Nicklaus v. Commissioner, 117 T.C. 117, 120-121 (2001).
Petitioners argue that the notice of deficiency issued to
them was invalid because, they assert, it lacked a valid
signature. We consider this argument frivolous. The Secretary
or his delegate is authorized by statute to issue notices of
deficiency, secs. 6212(a), 7701(a)(11)(B) and (12)(A)(i), and it
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