Michael J. Yacksyzn - Page 12




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          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).                           





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