Robert R. Villwock - Page 13

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               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            
          imposed therein.  Roberts v. Commissioner, 118 T.C. 365, 371 n.10           
          (2002); Weishan v. Commissioner, T.C. Memo. 2002-88; Lindsey v.             
          Commissioner, T.C. Memo. 2002-87; Tolotti v. Commissioner, T.C.             
          Memo. 2002-86; Duffield v. Commissioner, T.C. Memo. 2002-53;                
          Kuglin v. Commissioner, T.C. Memo. 2002-51.  In this regard, we             
          observe that the transcripts of account on which the Appeals                
          officer relied contained all the information prescribed in                  
          section 301.6203-1, Proced. & Admin. Regs.  See Weishan v.                  
          Commissioner, supra; Lindsey v. Commissioner, supra; Tolotti v.             
          Commissioner, supra; Duffield v. Commissioner, supra; Kuglin v.             
          Commissioner, supra.4                                                       

               4  To the extent that petitioner may still be arguing that             
          the Appeals officer failed to provide him with a copy of the                
          verification, we note that sec. 6330(c)(1) does not require that            
          the Appeals officer provide the taxpayer with a copy of the                 
          verification at the administrative hearing.  Nestor v.                      
          Commissioner, 118 T.C. 162, 166 (2002).  In any event, the record           
          shows that petitioner received both a literal transcript and a              
          Form 4340 for the taxable year 1997.                                        

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