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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. Some
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