David Andrew and Kathleen Stilwell Schmith - Page 14




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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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