-8- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011