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OPINION
Petitioner argues that because the assessment was made on
the RACS report rather than Form 23C, Summary Record of
Assessments, no valid assessment exists and because the Appeals
officer did not review a Form 23C she did not verify the
assessment as required by section 6330. Petitioner further
argues that review of a transcript of account is insufficient
verification for the purposes of section 6330.
Section 6330(c)(1) does not require the Commissioner to rely
on a particular document to satisfy the verification requirement
imposed therein. E.g., Schnitzler v. Commissioner, T.C. Memo.
2002-159 (citing five other cases to support this principle). We
have repeatedly held that the Commissioner may rely on
transcripts of account to satisfy the verification requirement of
section 6330(c)(1). Id.; Kaeckell v. Commissioner, T.C. Memo.
2002-114; Obersteller v. Commissioner, T.C. Memo. 2002-106;
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.
Additionally, we have held that the use of a RACS report,
instead of a Form 23C, in making an assessment does not
constitute an irregularity in respondent’s assessment procedure.
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Last modified: May 25, 2011