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Fifth Circuit has remarked: “We perceive no need to refute these
arguments with somber reasoning and copious citation of
precedent; to do so might suggest that these arguments have some
colorable merit.” Crain v. Commissioner, 737 F.2d 1417, 1417
(5th Cir. 1984). Suffice it to say that petitioner is a taxpayer
who is subject to the Federal income tax on his wages and other
sources of income. See secs. 1(c), 61(a)(1), (11), 7701(a)(1),
(14); Nestor v. Commissioner, 118 T.C. 162, 165 (2002).
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
account with regard to petitioner’s taxable years 1992 to 1997
and 1999.
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. Weishan v. Commissioner, T.C. Memo. 2002-88;
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