- 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
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