-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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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