Joseph T. Tornichio - Page 11




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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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