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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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