-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.
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