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properly in issue, we review respondent’s determination for an
abuse of discretion. Sego v. Commissioner, supra at 610.
Petitioner appears to argue that at the hearing she was not
provided documents demonstrating that the verification
requirement of section 6330 had been met. At the hearing, the
Commissioner is not required to provide the taxpayer with a copy
of verification that the requirements of any applicable law or
administrative procedure had been met. Nestor v. Commissioner,
118 T.C. 162, 166-167 (2002). In any event, petitioner has
received copies of her transcripts of account for the years in
issue. See Villwock v. Commissioner, T.C. Memo. 2002-235 n.4.
Accordingly, we conclude that respondent did not abuse his
discretion by not providing this information to petitioner at the
hearing.
Petitioner also appears to argue that the documents
furnished to her fail to show that the verification requirement
of section 6330 has been met. Section 6330(c)(1) does not
require the Commissioner to rely on a particular document to
satisfy the verification requirement imposed therein. E.g.,
Schnitzler v. Commissioner, T.C. Memo. 2002-159 (citing five
other cases to support this principle). We have repeatedly held
that the Commissioner may rely on transcripts of account to
satisfy the verification requirement of section 6330(c)(1). Id.;
Kaeckell v. Commissioner, T.C. Memo. 2002-114; Obersteller v.
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