-13-
importantly, in this case, petitioner not only received copies
of the MFTRA-X transcripts but also Forms 4340. Even standing
alone, the MFTRA-X transcripts, which were reviewed by the
Appeals officer, are a valid verification that the requirements
of any applicable law or administrative procedure have been met.4
Roberts v. Commissioner, 118 T.C. 365 (2002); Mudd v.
Commissioner, T.C. Memo. 2002-204; Howard v. Commissioner, T.C.
Memo. 2002-81; Mann v. Commissioner, T.C. Memo. 2002-48. We hold
that the Appeals officer satisfied the verification requirement
of section 6330(c)(1). Yacksyzn v. Commissioner, T.C. Memo.
2002-99; cf. Nicklaus v. Commissioner, 117 T.C. 117, 120-121
(2001).
Petitioner has failed to raise any arguments which have not
been previously rejected by this Court. Moreover, petitioner was
offered an opportunity for a hearing. By virtue of his own
volition, however, petitioner attempted to delay a hearing
4 Federal tax assessments are formally recorded on a record
of assessment. Sec. 6203. The summary record of assessment must
“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. The Forms 4340 and MFTRA-X transcripts received by
petitioner contained all this information. Petitioner has not
demonstrated in this proceeding any irregularity in the
assessment procedure that would raise a question about the
validity of the assessment or the information contained in the
Forms 4340 and MFTRA-X transcripts. See Mann v. Commissioner,
T.C. Memo. 2002-48. We hold that the assessment made by
respondent is valid. See Kuglin v. Commissioner, T.C. Memo.
2002-51; see also Duffield v. Commissioner, T.C. Memo. 2002-53.
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