Wayne A. and Marykay Weishan - Page 9




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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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