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petitioner received notice of the assessment as required by
section 6303.
Petitioner argues that the notice of determination on its
face reveals that the verification requirement of section
6330(c)(1) was not met. The notice of determination indicates
that Forms 4340 for the years at issue were not in the possession
of the Appeals officer during the face-to-face meeting with
petitioner. However, the notice further states that the Appeals
officer “reviewed the administrative file and the transcripts of
the liability” in determining whether the proposed levy was
“legally and procedurally correct”.
To the extent the notice of determination may leave any
ambiguity concerning the documentation used by the Appeals
officer to comply with section 6330(c)(1), we are nonetheless
satisfied, based on our review of the certified copies of the
Forms 4340 submitted by respondent in support of his motion, that
the requirements of applicable law or administrative procedure
have been met with respect to the amounts that respondent seeks
to collect herein. Section 6330(c)(1) does not require the
Appeals officer to rely upon a particular document (e.g., a Form
4340 rather than transcripts of account) in order to satisfy the
verification requirement. Craig v. Commissioner, 119 T.C. 252,
261-262 (2002). The Forms 4340 in the record indicate that
assessments of the unpaid liability were made on February 25,
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Last modified: May 25, 2011