Ginger Harmornick - Page 10

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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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