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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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