Tommy Ray Smith - Page 12




                                       - 12 -                                         
          on a particular document to satisfy the verification requirement            
          imposed by that section.3  Craig v. Commissioner, supra at 261-             
          262.  Form 4340 is a valid verification that the requirements of            
          any applicable law or administrative procedure have been met.               
          Id. at 262.  Petitioner has not shown any irregularity in respon-           
          dent’s assessment procedure that would raise a question about the           
          validity of the assessment or the information contained in Form             
          4340 with respect to petitioner’s taxable year 1997.  We hold               
          that the assessment with respect to petitioner’s taxable year               
          1997 was valid and that the Appeals officer satisfied the verifi-           
          cation requirement of section 6330(c)(1).  See id.4                         
               Based upon our examination of the entire record before us,             
          we find that respondent did not abuse respondent’s discretion in            

               3Nor does sec. 6330(c)(1) require the Appeals officer to               
          provide petitioner with a copy of the verification upon which the           
          Appeals officer relied.  Craig v. Commissioner, 119 T.C. 252, 262           
          (2002).                                                                     
               4We shall not specifically address any additional matters,             
          such as the following, which petitioner asserts in petitioner’s             
          response, all of which, as indicated above, the Court finds to be           
          frivolous and/or groundless:                                                
                    This Court has repeatedly ignored taxpayers’                      
               requests that this Court identify the IR Code Section                  
               that establishes a liability for the income tax, by                    
               simply stating that this argument is “frivolous”,                      
               instead of citing the alleged Code Section itself, if                  
               it exists. * * * Also, there is no entry under the                     
               “liability” heading in the index of the Internal Reve-                 
               nue Code for “income tax”. * * * This Court has repeat-                
               edly refused to produce proper, legal delegations of                   
               authority from the Secretary to various employees of                   
               the IRS * * *                                                          





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

Last modified: May 25, 2011