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officer to provide petitioner with a copy of the verification
upon which the settlement officer relied. Id. at 262. Form 4340
is a valid verification that the requirements of any applicable
law or administrative procedure have been met. Id. 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 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 settlement officer satisfied the verification requirement of
section 6330(c)(1). See id.5
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
unpaid liability for 1998.
In respondent’s motion, respondent requests that the Court
require petitioner to pay a penalty to the United States pursuant
5In petitioner’s response, petitioner also argues that
“Appeals personnel denied Petitioner the right to protect her
rights in total disregard for the Taxpayer Bill of Rights,
Publication 1 and Petitioner’s constitutional right to protect
oneself.” That is because, according to petitioner, the Appeals
Office denied her request to record her Appeals Office hearing.
However, petitioner admits that she “did in fact tape the CDP
hearing”, and we shall not address petitioner’s argument about
the Appeals Office’s refusal to permit her to record her Appeals
Office hearing.
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