- 11 - SWIFT, J., concurring: Arguably, the majority opinion treats all “assessment records” as if they are the same, and states overly broadly (majority op. p. 8) that “Section 6330(c)(1) does not require the Appeals officer to give the taxpayer a copy of the verification that the requirements of any applicable law or administrative procedure have been met.” The quoted language is susceptible of being read to mean that Appeals officers need not give or show to taxpayers copies of computerized transcripts of account or Forms 4340. Surely, we need not so hold in this case. Petitioner is not making that argument. At the Appeals hearing herein, the Appeals officer had a copy of the computerized transcript of account or Forms 4340 relating to petitioner, and nothing in the opinion suggests that the Appeals officer refused to provide petitioner with a copy of those specific documents.1 1 Repeatedly, in connection with the Appeals hearing and the litigation herein, petitioner insisted that he be provided not with a transcript of account or a Form 4340, but rather with a Form 23C and with the Summary Record of Assessment “as provided for in sec. 301.6203-1, Proced. & Admin. Regs.” At the Appeals hearing, petitioner was not interested in obtaining from respondent a copy of the transcript of account or the Form 4340. Like many other tax protesters, petitioner does not regard a computerized transcript of account or a Form 4340 as satisfying either the verification requirements of sec. 6330(c)(1) or the documentation provisions of sec. 301.6203-1, Proced. & Admin. Regs. E.g., Lunsford v. Commissioner, 117 T.C. 183, 187-189 (2001); Davis v. Commissioner, 115 T.C. 35, 40-41 (2000).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011