Danney R. Land - Page 14




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          requirements of all applicable laws and administrative procedures           
          were met as required by section 6330(c)(1).  The record shows               
          that prior to the administrative hearing on October 4, 2001, the            
          Appeals officer obtained and reviewed Form 4340 for petitioner’s            
          taxable year 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 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.             
          Commissioner, T.C. Memo. 2002-87; Tolotti v. Commissioner, supra;           
          Duffield v. Commissioner, T.C. Memo. 2002-53; Kuglin v.                     
          Commissioner, T.C. Memo. 2002-51.  In this regard, we observe               
          that the Form 4340 on which the Appeals officer relied contained            
          all the information prescribed in section 301.6203-1, Proced. &             
          Admin. Regs.  See Weishan v. Commissioner, supra; Lindsey v.                
          Commissioner, supra; Tolotti v. Commissioner, supra; Duffield v.            










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