- 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