Annie W. Nebres - Page 6

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          authority from the Secretary to the person (other than the                  
          Secretary) who signed the verification required under section               
          6330(c)(1).  Nestor v. Commissioner, 118 T.C. 162, 166-167                  
          (2002).  Similarly, the Appeals officer is not required to give             
          the taxpayer a copy of the verification that the requirements of            
          any applicable law or administrative procedure have been met.               
          Id. at 166; sec. 6330(c)(1).  Section 301.6330-1(e)(1), Proced. &           
          Admin. Regs., requires that the Appeals officer obtain                      
          verification before issuing the determination, not that he or she           
          provide it to the taxpayer.  In any event, before the trial in              
          this case, respondent’s counsel gave petitioner a copy of the               
          Form 4340 relating to petitioner’s 1996 tax year.  The Form 4340            
          that respondent gave petitioner before trial showed that the                
          amounts at issue were properly assessed, and petitioner did not             
          show at trial any irregularity in the assessment procedure that             
          would raise a question about the validity of the assessments.               
          There is no requirement that the notice of intent to levy or the            
          Appeals officer identify the Code sections which establish the              
          taxpayer’s liability for tax, additions to tax, or penalties.               
          Nestor v. Commissioner, supra at 167.                                       
               Finally, we reject petitioner’s contention that respondent             
          did not issue the notice and demand required by section 6303(a).            
          Respondent sent to petitioner a notice of balance due on May 29,            
          2000, the same day on which respondent assessed petitioner’s tax            






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