- 11 - 2. Verification Requirements Petitioner contends that the Appeals officer failed to obtain verification from the Secretary that the requirements of all applicable laws and administrative procedures had been met under section 6330(c)(1). This contention is without merit. Federal tax assessments are formally recorded on a record of assessment. Sec. 6203. “The summary record, through supporting records, shall 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. Roberts v. Commissioner, 118 T.C. 365, 371 n.10 (2002); Kaeckell v. Commissioner, T.C. Memo. 2002-114; Weishan v. Commissioner, T.C. Memo. 2002-88; Kuglin v. Commissioner, T.C. Memo. 2002-51. Moreover, section 6330(c)(1) does not require the Appeals officer to provide the taxpayer with a copy of the verification at the hearing. Sec. 301.6330- 1(e)(1), Proced. & Admin. Regs.; see also Nestor v. Commissioner, supra at 166. According to petitioner’s purported transcript of the Appeals Office hearing, the Appeals officer reviewed, among other things, transcripts of petitioner’s account for the years at issue in determining that the taxes were properly assessed. SomePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011