Larry A. Michael - Page 13




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          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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