John Thurman Horejs - Page 10

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          these arguments have some colorable merit.”  Crain v.                       
          Commissioner, 737 F.2d 1417, 1417 (5th Cir. 1984).  Suffice it to           
          say that petitioner is a taxpayer subject to the Federal income             
          tax, see secs. 1(a)(1), 7701(a)(1), (14), and that compensation             
          for labor or services rendered constitutes income subject to the            
          Federal income tax, see sec. 61(a)(1); United States v. Romero,             
          640 F.2d 1014, 1016 (9th Cir. 1981).                                        
               We likewise reject petitioner’s argument that the Appeals              
          officer failed to obtain verification from the Secretary that the           
          requirements of all applicable laws and administrative procedures           
          were met as required by section 6330(c)(1).  The record shows               
          that the Appeals officer obtained and reviewed transcripts of               
          account, including Forms 4340, with regard to petitioner’s                  
          taxable years 1995 and 1996.                                                
               Federal tax assessments are formally recorded on a record of           
          assessment.  Sec. 6203.  “The summary record, through supporting            
          records, shall provide identification of the taxpayer, the                  
          character of the liability assessed, the taxable period, if                 
          applicable, and the amount of the assessment.”  Sec. 301.6203-1,            
          Proced. & Admin. Regs.                                                      
               Section 6330(c)(1) does not require the Commissioner to rely           
          on a particular document to satisfy the verification requirement            
          imposed therein.  Roberts v. Commissioner, 118 T.C. 365, 371 n.10           
          (2002); Weishan v. Commissioner, T.C. Memo. 2002-88; Lindsey v.             

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