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a notice of intent to levy which explained their right to a
hearing.
For 1995 year, the Appeals officer verified that respondent
had issued a statutory notice of deficiency and petitioners had
not filed a petition. These matters were reflected on a
computerized transcript of petitioners’ 1995 account. Respondent
may use the transcript of account to verify the regularity of
these matters. Kuglin v. Commissioner, T.C. Memo. 2002-51.
For taxable years 1996 and 1997, the Appeals officer relied
on the fact that petitioners self-assessed the income tax
liability and that the examination division had considered and
denied petitioners’ claims that they owed no tax on the fishing
activity receipts.
Respondent has satisfied the section 6330 requirement to
verify that the prerequisites were met for proceeding to collect
the tax liability for 1995, 1996, and 1997.
There was no abuse of discretion in respondent’s
determination to proceed with collection of petitioners’
outstanding 1995-97 tax liabilities. The Appeals officer
verified that all legal and administrative procedures were met.
The verification was accomplished by means of a Form 4340,
Certificate of Assessments and Payments, which we have held is an
acceptable means of verification. Davis v. Commissioner, 115
T.C. 35, 41 (2000); see also Nestor v. Commissioner, 118 T.C. 162
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Last modified: May 25, 2011