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taxable years 1993 through 1997.
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. n.10
(2002); Weishan v. Commissioner, T.C. Memo. 2002-88; Lindsey v.
Commissioner, T.C. Memo. 2002-87; Tolotti v. Commissioner, T.C.
Memo. 2002-86; Duffield v. Commissioner, T.C. Memo. 2002-53;
Kuglin v. Commissioner, T.C. Memo. 2002-51. In this regard, we
observe that the transcripts of account on which the Appeals
officer relied, and which she furnished to petitioners during the
hearing, 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. Commissioner, supra; Kuglin v. Commissioner,
supra.3
3 In their motion to dismiss, see supra p. 11, petitioners
alleged that the Appeals officer did not provide them with a copy
of the verification. We note that sec. 6330(c)(1) does not
(continued...)
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