- 7 - In respondent’s motion, respondent contends that the Appeals officer’s reliance on the transcripts to verify that respondent made a valid assessment with respect to petitioner’s taxable year 1995 satisfies the requirements of section 6330(c)(1) that the Appeals officer obtain verification that the requirements of any applicable law or administrative procedure have been met. That is because, according to respondent, (1) those transcripts contained all of the information required under section 301.6203- 1, Proced. & Admin. Regs.,5 and (2) petitioner failed to show any 4(...continued) the Virgin Islands. * * * * * * * * * * 22. The only regulations promulgated by the Secretary to implement his collection authority are found at 27 CFR Part 70 and pertains only to matters re- garding alcohol, tobacco and firearms. * * * * * * * 26. The Service is not in possession of any record maintained under the Privacy Act that shows that the Affiant is a “Taxpayer”. 27. The Service is not in possession of any record maintained under the Privacy Act that the Affiant has ever “volunteered” (without treats, duress and coercion by the Service) to file a federal 1040 tax return. 5Sec. 301.6203-1, Proced. & Admin. Regs., provides in perti- nent part: The assessment shall be made by an assessment officer signing the summary record of assessment. The summary record, through supporting records, shall provide (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011