Thomas Lou Harris - Page 3

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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).                         
               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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