- 13 - 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. InPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011