Joseph T. Tornichio - Page 12




                                        - 12 -                                        
          5 months before trial, respondent sent petitioner “Plain English”           
          computer transcripts of his account.  In addition, as part of the           
          pretrial stipulation process, respondent provided petitioner with           
          copies of so-called TXMODA transcripts of account.5  These various          
          transcripts of petitioner’s account, which are part of the record           
          in this case, contain all the information prescribed in section             
          301.6203-1, Proced. & Admin. Regs.  See Schroeder v.                        
          Commissioner, T.C. Memo. 2002-190; Kaeckell v. Commissioner,                
          supra; Weishan v. Commissioner, supra.6                                     
               Petitioner has shown no 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.  See Nestor v. Commissioner, supra at 167; Davis v.                
          Commissioner, 115 T.C. 35, 41 (2000).  Accordingly, we hold that            
          respondent satisfied the verification requirement of section                
          6330(c)(1).                                                                 




               5 A TXMODA transcript contains current account information             
          obtained from the Commissioner’s master file.  “TXMODA” is the              
          command code that is entered into the Commissioner’s integrated             
          data retrieval system (IDRS) to obtain the transcript.  IDRS is             
          essentially the interface between the Commissioner’s employees              
          and the Commissioner’s various computer systems.  See Kaeckell v.           
          Commissioner, T.C. Memo. 2002-114, n.2.                                     
               6 The record does not reveal the particular type of                    
          transcript relied upon by the Appeals officer, but we regard this           
          matter as irrelevant.  See Keene v. Commissioner, T.C. Memo.                
          2002-277, n.10.                                                             





Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  Next

Last modified: May 25, 2011