Lance Standifird - Page 8




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          received copies of the MFTRA-X transcript but also Forms 43403              
          and TXMODA transcripts.  Even standing alone, the MFTRA-X                   
          transcript, which was reviewed by the Appeals officer at the                
          hearing, is a valid verification that the requirements of any               
          applicable law or administrative procedure have been met.4                  
          Roberts v. Commissioner, 118 T.C. 365 (2002); Mudd v.                       
          Commissioner, T.C. Memo. 2002-204; Howard v. Commissioner, T.C.             
          Memo. 2002-81; Mann v. Commissioner, T.C. Memo. 2002-48.  We hold           
          that the Appeals officer satisfied the verification requirement             
          of section 6330(c)(1).  Yacksyzn v. Commissioner, T.C. Memo.                
          2002-99; cf. Nicklaus v. Commissioner, 117 T.C. 117, 120-121                
          (2001).                                                                     
               Petitioner further contends that he did not receive “the               
          notices of assessment for the alleged assessment of the income              


               3 Petitioner is not prejudiced by the fact that he received            
          Forms 4340 after the Appeals Office hearing.  Nestor v.                     
          Commissioner, 118 T.C. 162, 167 (2002).                                     
               4 Federal tax assessments are formally recorded on a record            
          of assessment.  Sec. 6203.  The summary record of assessment must           
          “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.  The MFTRA-X transcript received by petitioner at the                 
          Appeals Office hearing contained all this information.                      
          Petitioner has not demonstrated in this proceeding any                      
          irregularity in the assessment procedure that would raise a                 
          question about the validity of the assessment or the information            
          contained in the MFTRA-X transcript.  See Mann v. Commissioner,             
          T.C. Memo. 2002-48.  We hold that the assessment made by                    
          respondent is valid.  See Kuglin v. Commissioner, T.C. Memo.                
          2002-51; see also Duffield v. Commissioner, T.C. Memo. 2002-53.             





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