Emil P. Tolotti, Jr. - Page 14

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          this regard, we note that the transcripts of account on which the           
          Appeals officer relied in this case contained all the information           
          prescribed in section 301.6203-1, Proced. & Admin. Regs.  Id.               
          Moreover, the Form 4340 substantiates the information contained             
          in the transcripts of account.                                              
              Petitioner has not alleged any irregularity in the                     
          assessment procedure that would raise a question about the                  
          validity of the assessments or the information contained in the             
          transcripts of account or the Form 4340.  Id.; Mann v.                      
          Commissioner, T.C. Memo. 2002-48.  Accordingly, we hold that the            
          Appeals officer satisfied the verification requirement of section           
          6330(c)(1).  Cf. Nicklaus v. Commissioner, 117 T.C. 117, 120-121            
               Petitioner has failed to raise a spousal defense, make a               
          valid challenge to the appropriateness of respondent’s intended             
          collection action, or offer alternative means of collection.                
          These issues are now deemed conceded.  Rule 331(b)(4).  In the              
          absence of a valid issue for review, we conclude that respondent            
          is entitled to judgment as a matter of law sustaining the notice            
          of determination dated February 16, 2001.                                   
               Finally, we mention section 6673(a)(1), which authorizes the           
          Tax Court to require a taxpayer to pay to the United States a               
          penalty not in excess of $25,000 whenever it appears that                   
          proceedings have been instituted or maintained by the taxpayer              

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