Jose A. Perez - Page 11

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          Examination Assessments                                                     
               While petitioner is not foreclosed from contesting the                 
          examination assessments,5 his arguments are unavailing.                     
          Petitioner argues herein that the assessments were invalid                  
          because the Appeals officer did not rely on or provide to him a             
          Form 23C, Summary Record of Assessment, for purposes of verifying           
          that the assessments were valid.  This argument is without merit.           
          The Appeals officer used an MFTRA-X transcript, a copy of which             
          she provided to petitioner at the hearing, to verify that the               
          assessments petitioner challenges, including the examination                
          assessments, were validly made.  Absent some showing of                     
          irregularity in respondent’s assessment procedures that raises a            
          question about the validity of respondent’s assessments of                  
          petitioner’s tax liabilities, which petitioner has not made, it             
          is not an abuse of discretion for an Appeals officer to verify an           
          assessment by means of an MFTRA-X transcript.  Standifird v.                
          Commissioner, T.C. Memo. 2002-245; Holliday v. Commissioner, T.C.           
          Memo. 2002-67.  The MFTRA-X transcripts contain all information             
          necessary to the recordation of an assessment under respondent’s            
          regulations, including the identification of the taxpayer, the              
          character of the liability assessed, the taxable period, and the            

               5 Certain of the issues raised by petitioner in the instant            
          proceedings under sec. 6330(d) were not raised by him in his                
          request for a hearing or at the hearing.  Since all such issues             
          lack merit, we need not decide whether petitioner is entitled to            
          raise them in the instant proceedings.                                      

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