- 12 - and reviewed transcripts of account for petitioner’s taxable year 1997. 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. Duffield v. Commissioner, T.C. Memo. 2002-53; Kuglin v. Commissioner, T.C. Memo. 2002-51. In this regard, we observe that the transcripts of account on which the Appeals officer relied, and which he furnished to petitioner before the hearing, contained all the information prescribed in section 301.6203-1, Proced. & Admin. Regs. See Duffield v. Commissioner, supra; Kuglin v. Commissioner, supra.6 Petitioner has not alleged any irregularity in the assessment procedure that would raise a question about the validity of the assessments or the information contained in the transcripts of account. See id.; Mann v. Commissioner, T.C. Memo. 2002-48. Accordingly, we hold that the Appeals officer 6 We note that sec. 6330(c)(1) also does not require the Commissioner to give the taxpayer a copy of the verification. Nestor v. Commissioner, 118 T.C. 162, 166 (2000).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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