- 12 -
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 transcript 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.5
Petitioners have not alleged any irregularity in the
assessment procedure that would raise a question about the
validity of the assessments or the information contained in the
transcript of account. See Davis v. Commissioner, supra at 41;
Mann v. Commissioner, T.C. Memo. 2002-48. Accordingly, we hold
that the Appeals officer satisfied the verification requirement
of section 6330(c)(1). Cf. Nicklaus v. Commissioner, 117 T.C.
117, 120-121 (2001).
Petitioners also contend that they never received a notice
5 To the extent that petitioners may still be arguing that
the Appeals officer failed to provide them 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 the Appeals officer provided petitioners with a
transcript of account prior to the Appeals Office hearing.
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