James E. Anderson and Cheryl J. Latos - Page 18

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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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