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of account constitute valid verification that the requirements of
any applicable law or administrative procedure have been met, see
Roberts v. Commissioner, 118 T.C. 365, 371-372 n.10 (2002), as
does Form 4340, Craig v. Commissioner, supra at 262. Petitioner
has not shown any irregularity in respondent’s assessment proce-
dure that would raise a question about the validity of the
assessment or the information contained in the transcripts of
account or Form 4340 with respect to petitioner’s taxable year
1998. We hold that the assessment with respect to petitioner’s
taxable year 1998 was valid and that the Appeals officer satis-
fied the verification requirement of section 6330(c)(1). See
id.; Roberts v. Commissioner, supra.2
Based upon our examination of the entire record before us,
we find that respondent did not abuse respondent’s discretion in
determining to proceed with the collection action as determined
in the notice of determination with respect to petitioner’s
taxable year 1998.
2We shall not specifically address any additional matters,
such as the following, which petitioner asserts in petitioner’s
response, all of which, as indicated above, the Court finds to be
frivolous and/or groundless:
d. Since all valid assessments must emanate from
a filed return, proof that such a “filed return” exists
is another “relevant” issue that taxpayers can raise.
If this issue is raised, then, obviously, it is incum-
bent upon the appeals officer to produce the return
from which the claimed assessment was made - if this
“relevant” issue is raised by the taxpayer - especially
if it was raised on his request for a CDP hearing.
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