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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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