Rainer B. and Sonja D. Wagner - Page 12

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          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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