- 6 - 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 taxPage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011