Susan P. Obersteller - Page 4




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          respect to petitioner’s assessed and unpaid taxes for 1992 and              
          1993 was sustained.                                                         
               On June 15, 2001, petitioner filed, under section                      
          6330(d)(1), a petition for judicial review of the above final               
          determination made by respondent regarding collection of                    
          petitioner’s assessed and unpaid taxes for 1992 and 1993.  On               
          July 16, 2001, petitioner filed an amended petition.                        

                                     Discussion                                       
               Petitioner asserts that, because respondent refused to                 
          provide a copy of a signed “Form 23C” at the collection hearing,            
          respondent’s Appeals officer failed to properly verify under                
          section 6330(c)(1) that respondent’s lien filing met the                    
          requirements of “any applicable law or administrative procedure”.           
               We have repeatedly held that, absent irregularities,                   
          respondent may rely on Forms 4340 and transcripts of account for            
          the purpose, under section 6330(c)(1), of verifying data relevant           
          to respondent’s assessments of tax deficiencies against                     
          taxpayers.  Nestor v. Commissioner, 118 T.C. 162, 166 (2002);               
          Lindsey v. Commissioner, T.C. Memo. 2002-87; Howard v.                      
          Commissioner, T.C. Memo. 2002-81; Holliday v. Commissioner, T.C.            
          Memo. 2002-67; Duffield v. Commissioner, T.C. Memo. 2002-53; Mann           
          v. Commissioner, T.C. Memo. 2002-48.                                        
               In the alternative, petitioner asserts generally that she              
          did not receive the type of “due process” hearing that is                   





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