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Court of Appeals for the Fifth Circuit has remarked: “We perceive
no need to refute these arguments with somber reasoning and
copious citation of precedent; to do so might suggest that these
arguments have some colorable merit.” Crain v. Commissioner, 737
F.2d 1417, 1417 (5th Cir. 1984).
We likewise reject petitioner’s argument that the Appeals
officers failed to obtain verification from the Secretary that
the requirements of all applicable laws and administrative
procedures were met as required by section 6330(c)(1). The
record shows that the Appeals officers obtained and reviewed
Forms 4340 with regard to petitioner’s accounts for taxable years
1996 and 1998.
Federal tax assessments are formally recorded on a record of
assessment. Sec. 6203. “The summary record, through supporting
records, shall provide identification of the taxpayer, the
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
on a particular document to satisfy the verification requirement
imposed therein. Roberts v. Commissioner, 118 T.C. 365, 371 n.10
(2002); Weishan v. Commissioner, T.C. Memo. 2002-88; Lindsey v.
Commissioner, T.C. Memo. 2002-87; Tolotti v. Commissioner, T.C.
Memo. 2002-86; Duffield v. Commissioner, T.C. Memo. 2002-53;
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Last modified: May 25, 2011