Emil P. Tolotti, Jr. - Page 13

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          Federal Tax Lien in question is valid notwithstanding any                   
          additional provision that may exist under Nevada State law.                 
               We also reject petitioner’s assertions that the Appeals                
          officer was not impartial and/or conducted a sham hearing.  Such            
          assertions are belied by the record.  See sec. 6330(b)(3).                  
               Petitioner next contends that the Appeals officer failed to            
          obtain verification from the Secretary that the requirements of             
          all applicable laws and administrative procedures were met as               
          required by section 6330(c)(1).  We reject petitioner’s                     
          contention inasmuch as the record establishes that the Appeals              
          officer obtained and reviewed transcripts of account with regard            
          to petitioner’s taxable year 1995.  The record also includes a              
          Form 4340 that substantiates the information contained in the               
          transcripts of account.  See Davis v. Commissioner, 115 T.C. 35,            
          40-41 (2000) (Form 4340 is presumptive evidence that an                     
          assessment was made against the taxpayer).                                  
               Federal tax assessments are formally recorded on a summary             
          record of assessment.  Sec. 6203.  The summary 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.                   
               Section 6330(c)(1) does not require the Commissioner to rely           
          on a particular document to satisfy the verification requirement            
          imposed therein.  Kuglin v. Commissioner, T.C. Memo. 2002-51.  In           

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