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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...)
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Last modified: May 25, 2011