-8-
We disagree with petitioner’s allegation that the Appeals
officer failed to obtain the verification from the Secretary
required by section 6330(c)(1). Section 6330(c)(1) does not
require the Appeals officer to rely upon a particular document
(e.g., the summary record itself rather than transcripts of
account) in order to satisfy this verification requirement.
Kuglin v. Commissioner, T.C. Memo. 2002-51; see also Weishan v.
Commissioner, T.C. Memo. 2002-88. Nor does it mandate that the
Appeals officer actually give a taxpayer a copy of the
verification upon which the Appeals officer relied. Sec.
6330(c)(1); sec. 301.6330-1(e)(1), Proced. & Admin. Regs.; see
also Nestor v. Commissioner, 118 T.C. 162 (2002). Given the
additional fact that petitioner was actually given copies of the
relevant Forms 4340, which are a valid verification that the
requirements of any applicable law or administrative procedure
have been met, Roberts v. Commissioner, 118 T.C. 365 (2002); Mudd
v. Commissioner, T.C. Memo. 2002-204; Howard v. Commissioner,
T.C. Memo. 2002-81; Mann v. Commissioner, T.C. Memo. 2002-48, we
hold that: (1) The assessments were valid, Kuglin v.
Commissioner, supra; see also Duffield v. Commissioner, T.C.
Memo. 2002-53, and (2) the Appeals officer satisfied the
verification requirement of section 6330(c)(1), Yacksyzn v.
Commissioner, T.C. Memo. 2002-99; cf. Nicklaus v. Commissioner,
117 T.C. 117, 120-121 (2001). Petitioner has not demonstrated in
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