- 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.
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