Daniel A. Fink - Page 11




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          nature of petitioner’s position in this case, petitioner contends           
          in petitioner’s response that the Appeals officer failed to                 
          obtain and to produce verification that the requirements of any             
          applicable law or administrative procedure have been met, as                
          required by section 6330(c)(1).  The record establishes that the            
          Appeals officer obtained verification from the Secretary that the           
          requirements of any applicable law or administrative procedure              
          were met, and we reject petitioner’s contention to the contrary.            
          Prior to the Appeals Office hearing, the Appeals officer reviewed           
          complete computer transcripts of petitioner’s account and pro-              
          vided petitioner with a literal transcript of account with                  
          respect to petitioner’s taxable year 1998.  At the Appeals Office           
          hearing, the Appeals officer relied on transcripts of peti-                 
          tioner’s account with respect to petitioner’s taxable year 1998.            
          After the Appeals office hearing, respondent’s representative               
          provided petitioner with Form 4340 with respect to petitioner’s             
          taxable year 1998.  See Nestor v. Commissioner, 118 T.C. 162, 167           
          (2002).                                                                     
               Section 6330(c)(1) does not require the Appeals officer to             
          rely on a particular document to satisfy the verification re-               
          quirement imposed by that section.  Craig v. Commissioner, supra            
          at 261-262.  Nor does section 6330(c)(1) require the Appeals                
          officer to provide petitioner with a copy of the verification               
          upon which the Appeals officer relied.  Id. at 262.  Transcripts            






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