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On August 8, 2000, the Appeals office sent petitioner a
Notice of Determination Concerning Collection Action(s) under
Section 6320 and/or 6330 (determination) sustaining the proposed
collection action. Respondent relied on the transcripts to
verify the assessments. Prior to trial, respondent provided
petitioner with copies of Forms 4340, Certificate of Assessments,
Payments, and Other Specified Matters (Forms 4340).
Discussion
Section 6330(b)(1) provides that if a taxpayer requests a
hearing, “such hearing shall be held by the Internal Revenue
Service Office of Appeals.” Section 6330(c)(1) states: “The
appeals officer shall at the hearing obtain verification from the
Secretary that the requirements of any applicable law or
administrative procedure have been met.” Petitioner received the
notices of deficiency. Accordingly, the underlying liability is
not at issue. Sec. 6330(c)(2)(B).
Petitioner contends that the computer transcripts were not
adequate proof of assessment. Respondent contends that the
Appeals officer did not abuse his discretion by relying on the
transcripts to verify the assessments. We agree with respondent.
The transcripts contained the requisite information (i.e.,
“identification of the taxpayer, the character of the liability
assessed, the taxable period, if applicable, and the amount of
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