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motion for summary judgment is contrary to Rule 121(d) and
justifies summary judgment for respondent on this issue.
We likewise reject petitioner’s argument that the Appeals
officer failed to obtain verification from the Secretary that the
requirements of all applicable laws and administrative procedures
were met as required by section 6330(c)(1). The record shows
that the Appeals officer obtained and reviewed a transcript of
petitioner’s account for 1998.
Federal tax assessments are formally recorded on a record of
assessment. Sec. 6203. “The summary record, through supporting
records, shall provide identification of the taxpayer, the
character of the liability assessed, the taxable period, if
applicable, and the amount of the assessment.” Sec. 301.6203-1,
Proced. & Admin. Regs.
Section 6330(c)(1) does not require the Commissioner to rely
on a particular document (e.g., the summary record itself rather
than a transcript of account) to satisfy the verification
requirement imposed therein. Roberts v. Commissioner, 118 T.C.
365, 371 n.10 (2002); Standifird v. Commissioner, T.C. Memo.
2002-245; Weishan v. Commissioner, T.C. Memo. 2002-88; Lindsey v.
Commissioner, T.C. Memo. 2002-87; Tolotti v. Commissioner, T.C.
Memo. 2002-86; Duffield v. Commissioner, T.C. Memo. 2002-53;
Kuglin v. Commissioner, T.C. Memo. 2002-51. In this regard, we
observe that the Form 4340 furnished to petitioner by the Appeals
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