Andy Hromiko - Page 7

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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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