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that prior to the administrative hearing on August 21, 2001, the
Appeals officer obtained and reviewed Form 4340 for petitioners’
taxable year 1997.
Federal tax assessments are formally recorded on a record of
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 requirements
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, supra;
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.6
6 To the extent that petitioners may still be arguing that
the Appeals officer failed to provide them 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
(continued...)
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