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Section 6330(c)(1) does not require the Commissioner to rely
on a particular document (e.g., the summary record itself rather
than transcripts of account) to satisfy the verification
requirement imposed therein. Roberts v. Commissioner, 118 T.C.
365, 371 n.10 (2002); Standifird v. Commissioner, T.C. Memo.
2002-245; 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. In this regard, we
observe that the literal transcripts furnished to petitioner and
the Forms 4340 attached to respondent’s Declaration contained all
the information prescribed in section 301.6203-1, Proced. &
Admin. Regs.10 See Weishan v. Commissioner, supra; Lindsey v.
Commissioner, supra; Tolotti v. Commissioner, supra; Duffield v.
10 The record does not definitively disclose the type of
transcript that the Appeals officer reviewed prior to the
administrative hearing on Feb. 6, 2002. The Appeals officer may
have reviewed the literal transcripts that he furnished to
petitioner or, more likely given the fact that such transcripts
are typically prepared for use by taxpayers unfamiliar with IRS
computer codes, he may have reviewed TXMOD-A transcripts. See
Schroeder v. Commissioner, T.C. Memo. 2002-190 n.3, for a
description of such transcripts. In any event, we regard the
matter to be irrelevant. See Hack v. Commissioner, T.C. Memo.
2002-243 (“The use of computer-generated transcripts of account
is a valid verification that the requirements of any applicable
law or administrative procedure have been met.”); Hauck v.
Commissioner, T.C. Memo. 2002-184 (“We have repeatedly held that
the Commissioner may rely on transcripts of account to satisfy
the verification requirement of section 6330(c)(1).”).
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