Christopher Kiley - Page 21

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          justifies summary judgment for respondent on this issue.                    
               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               
          petitioner’s accounts for 1995, 1997, and 1998.                             
               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 (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 Forms 4340 furnished to petitioner by the                  
          Appeals officer and attached to respondent’s Declaration                    

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