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assessment, by respondent with respect to that year. Having
shown what petitioner maintains is an irregularity in respon-
dent’s assessment procedure with respect to his taxable year
1996, petitioner further argues that the Appeals officer’s
reliance on Form 4340 to verify that respondent made a valid
assessment with respect to that year does not satisfy the re-
quirements of section 6330(c)(1) that the Appeals officer obtain
verification that the requirements of any applicable law or
administrative procedure have been met.7
We reject petitioner’s position. As petitioner is aware
from Lester v. United States, No. 13-96-15835 MA, Adv. No. 97-
1078M (D.N.M. July 7, 1998), which he cites in petitioner’s
motion and in petitioner’s response to respondent’s motion,
respondent has for a number of years been engaged in making a
transition in respondent’s assessment procedure from the general
use of a manually prepared Form 23C to the general use of RACS
7While not altogether clear, petitioner may also be arguing
that respondent’s assessment with respect to petitioner’s taxable
year 1996 may not be valid because he did not receive certain
documentation to which he is entitled under sec. 6203 and sec.
301.6203-1, Proced. & Admin. Regs. Respondent provided peti-
tioner with a copy of Form 4340 with the notice of determination.
That form set forth, inter alia, petitioner’s name, the date of
assessment, the character of the liability assessed, the taxable
period, and the amounts assessed. We conclude that petitioner
has received the documentation to which he is entitled under sec.
6203 and sec. 301.6203-1, Proced. & Admin. Regs. See Koff v.
United States, 3 F.3d 1297, 1298 (9th Cir. 1993). That the
Appeals officer provided petitioner a copy of Form 4340 with the
notice of determination does not constitute an abuse of discre-
tion. See Nestor v. Commissioner, 118 T.C. 162 (2002).
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