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required by section 6330(c)(1). The record shows otherwise. In
particular, the Appeals officer obtained and reviewed
transcripts of account (Forms 4340) with regard to petitioner’s
taxable years 1990 through 1993.
Federal tax assessments are formally recorded on a record of
assessment. Sec. 6203. “The summary record, through supporting
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), on appeal (11th Cir. July 26, 2002); Weishan v.
Commissioner, T.C. Memo. 2002-88; Lindsey v. Commissioner, T.C.
Memo. 2002-87; Tolotti v. Commissioner, T.C. Memo. 2002-86;
Duffield v. Commissioner, T.C. Memo. 2002-53; Kuglin v.
Commissioner, T.C. Memo. 2002-51. In this regard, we observe
that the Forms 4340 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.
Petitioner has not alleged any irregularity in the
assessment procedure that would raise a question about the
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