- 9 - 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 disputePage: Previous 1 2 3 4 5 6 7 8 9 10 Next
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