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on a particular document to satisfy the verification requirement
contained therein. See, e.g., Hauck v. Commissioner, T.C. Memo.
2002-184, affd. 64 Fed. Appx. 492 (6th Cir. 2003). It is well
established that the Commissioner may rely on transcripts of
account to satisfy the section 6330(c)(1) verification
requirement. See id. (and cases cited therein). Section
6330(c)(1) does not require the Appeals officer to provide the
taxpayer with a copy of the verification at the hearing. Sec.
301.6330-1(e)(1), Proced. & Admin. Regs.; see Nestor v.
Commissioner, 118 T.C. 162, 166 (2002).
The administrative file developed by respondent’s Appeals
Office in connection with petitioner’s request for a collection
hearing contains, among other things, transcripts of petitioner’s
account for taxable year 1990. Among these transcripts are a so-
called IMFOLT file dated March 9, 2000, and a literal transcript
dated March 6, 2000. These transcripts indicate, among other
things, that petitioner filed no 1990 Federal income tax return,
and that on April 26, 1993, respondent made a substitute for
return and assessed petitioner’s 1990 income tax liability (and
related penalties and interest). The transcripts reflect no
payments on petitioner’s account other than the $10,583.24
credited to petitioner’s account on October 6, 1995 (the date
that respondent sold the property to ACI). The literal
transcript shows that this credit was reversed in 1998
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