Rainer B. and Sonja D. Wagner - Page 11

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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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