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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
upon a particular document (i.e., the summary record itself
rather than a transcript of account) to satisfy the verification
requirement imposed therein. Kuglin v. Commissioner, T.C. Memo.
2002-51. In this regard, we note that the transcript of account
that the Appeals officer relied upon in this case contained all
the information prescribed in section 301.6203-1, Proced. &
Admin. Regs. Id.
Petitioners have not demonstrated 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 Mann v. Commissioner, T.C. Memo.
2002-48. Accordingly, we hold that the Appeals officer satisfied
the verification requirement imposed under section 6330(c)(1).
Petitioners have failed to raise a spousal defense, make a
valid challenge to the appropriateness of respondent’s intended
collection action, or offer alternative means of collection.
These issues are now deemed conceded. Rule 331(b)(4). In the
absence of a valid issue for review, and there being no dispute
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