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remarked: "We perceive no need to refute these arguments with
somber reasoning and copious citation of precedent; to do so
might suggest that these arguments have some colorable merit."
Crain v. Commissioner, 737 F.2d 1417, 1417 (5th Cir. 1984).
Suffice it to say that petitioners are taxpayers subject to
Federal income tax, see secs. 1(a)(1), 7701(a)(1), (14), and that
compensation for labor or services rendered constitutes income
subject to Federal income tax under section 61(a)(1), see United
States v. Romero, 640 F.2d 1014, 1016 (9th Cir. 1981).
We likewise reject petitioners’ argument that the Appeals
officer failed to obtain verification from the Secretary that the
requirements of all applicable laws and administrative procedures
were met as required by section 6330(c)(1). The record shows
that the Appeals officer obtained and reviewed a transcript of
account with regard to petitioners’ tax liability for 1997.
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. See Roberts v. Commissioner, 118 T.C. 365, 371
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