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Federal tax assessments are formally recorded on a summary
record of assessment. Sec. 6203. The summary record must
“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.
Contrary to petitioners’ position, section 6330(c)(1) does
not require the Commissioner to rely on a particular document to
verify that the requirements of any applicable law or
administrative procedure have been met in a collection matter.
See Kuglin v. Commissioner, T.C. Memo. 2002-51. Nor is
respondent obliged to provide the taxpayer with a copy of the
verification. See Nestor v. Commissioner, 118 T.C. 162, 166
(2002).
The record in this case shows that the settlement officer
obtained and reviewed IDRS transcripts of account with regard to
petitioners’ taxable years 1989 through 1993 prior to the Appeals
Office hearing. The IDRS transcripts of account contained all
the information prescribed in section 301.6203-1, Proced. &
Admin. Regs. Kuglin v. Commissioner, supra. The record also
includes Forms 4340 and TXMODA transcripts that serve to
supplement and substantiate the information contained in the IDRS
transcripts of account. See Davis v. Commissioner, supra at 40-
41 (Form 4340 is presumptive evidence that an assessment was made
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Last modified: May 25, 2011