- 8 -
administrative procedure has been met. Nestor v. Commissioner,
118 T.C. 162, 166-167 (2002). In any event, respondent gave
petitioner copies of his transcripts of account for the years in
issue at, and subsequent to, the hearing.
We have repeatedly held that the Commissioner may rely on
transcripts of account to satisfy the verification requirement of
section 6330(c)(1). E.g., Eiselstein v. Commissioner, T.C. Memo.
2003-22. 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. Davis v. Commissioner, 115 T.C. 35, 41
(2000); Mann v. Commissioner, T.C. Memo. 2002-48. Accordingly,
we hold that the verification requirement of section 6330(c)(1)
has been satisfied. Cf. Nicklaus v. Commissioner, 117 T.C. 117,
120-121 (2001).
Petitioner claims in the petition that he was not accorded a
hearing that complied with section 6330 because as part of the
hearing he was not able to summon witnesses, cross-examine
witnesses, conduct discovery, examine documents, or obtain
evidence from respondent. We have repeatedly held that section
6330 hearings are informal, and that the compulsory attendance of
witnesses or production of documents is not required. Katz v.
Commissioner, 115 T.C. 329, 337 (2000); Davis v. Commissioner,
supra at 41-42.
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011