- 3 - 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 ofPage: Previous 1 2 3 4 Next
Last modified: May 25, 2011