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require the Commissioner of Internal Revenue to rely on a partic-
ular document to satisfy the verification requirement imposed by
that section.7 We have held that, absent a showing by the tax-
payer of an irregularity in respondent’s assessment procedure, it
was not an abuse of discretion for the Appeals officer to have
relied on certain computer-generated transcripts for purposes of
complying with section 6330(c)(1).8 On the record before us, we
find 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 did not constitute an abuse of
discretion. On that record, we further find that the facts that
are undisputed for purposes of respondent’s motion establish that
petitioner received a fair hearing before an impartial decision
maker.
Based on our examination of the entire record before us, we
find that respondent did not abuse respondent’s discretion in
determining in the notice of determination to proceed with
collection with respect to petitioner’s taxable year 1995. On
that record, we shall grant respondent’s motion.
Although respondent has not requested a penalty under
section 6673(a)(1), this Court is authorized to impose such a
7E.g., Lindsey v. Commissioner, T.C. Memo. 2002-87; Kuglin
v. Commissioner, T.C. Memo. 2002-51.
8E.g., Howard v. Commissioner, T.C. Memo. 2002-81; Kuglin v.
Commissioner, supra; Mann v. Commissioner, T.C. Memo. 2002-48.
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