- 11 - 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. TranscriptsPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011