Vernice B. Kuglin - Page 4




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          verifying the assessments, may rely on computer transcripts that            
          contain the requisite information.                                          
               We agree with respondent.  Section 6203 authorizes the                 
          Secretary to make assessments.  The assessment officer, appointed           
          by the Secretary, makes the assessment by signing the summary               
          record of assessment.  Sec. 301.6203-1, Proced. & Admin. Regs.              
          The summary record of assessment must “provide identification of            
          the taxpayer, the character of the liability assessed, the                  
          taxable period, if applicable, and the amount of the assessment.”           
          Id.  Section 6330(c)(1), however, does not require that the                 
          Commissioner verify the information by using a particular source            
          (i.e., the summary record itself rather than a computer                     
          transcript).  The transcripts respondent used for the                       
          verification contained the requisite information.  Respondent’s             
          reliance on such transcripts was not an abuse of discretion.                
               Where the Commissioner provides the taxpayer with Forms 4340           
          (i.e., proof of assessment) after the hearing and before trial,             
          and the taxpayer does not “show at trial any irregularity in the            
          assessment procedure that would raise a question about the                  
          validity of the assessments”, the taxpayer is not prejudiced.               
          Nestor v. Commissioner, 118 T.C. ___, ___ (2002) (slip op. at 9).           
          At trial, petitioner did not show any irregularity in the                   
          assessment procedure.  Accordingly, we sustain respondent’s                 
          determination.                                                              






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