Harvey Doyne Perry, Jr. - Page 14

                                       - 14 -                                         
          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. 365, 371 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 Form 4340 on which the Appeals officer relied              
          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.8            
               Petitioner has not alleged any irregularity in the                     
          assessment procedure that would raise a question about the                  

               8  To the extent that petitioner may still be arguing that             
          the Appeals officer failed to provide him with a copy of the                
          verification, we note that sec. 6330(c)(1) does not require that            
          the Appeals officer provide the taxpayer with a copy of the                 
          verification at the administrative hearing.  Nestor v.                      
          Commissioner, 118 T.C. 162, 166 (2002).  In any event, the                  
          Appeals officer provided petitioner with a copy of Form 4340 for            
          the taxable year 1997.  Indeed, petitioner attached a copy of               
          this form as an exhibit to his petition.                                    

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  Next

Last modified: May 25, 2011