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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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