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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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Last modified: May 25, 2011