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We have repeatedly held that a Form 4340 or a computer
printout of a taxpayer’s transcript of account, absent a showing
of irregularity, provides sufficient verification of the
taxpayer’s outstanding liability (and that a valid assessment has
been made) to satisfy the requirements of section 6330(c)(1).
See, e.g., Davis v. Commissioner, 115 T.C. 35, 40-41 (2000);
Roberts v. Commissioner, T.C. Memo. 2004-100; Tornichio v.
Commissioner, T.C. Memo. 2002-291; Howard v. Commissioner, T.C.
Memo. 2002-81. In light of petitioner’s failure to demonstrate
any irregularity in the preparation of the transcripts of
petitioner’s account for 1990-1996, we find that those
transcripts accurately reflect the assessed liabilities and
payments thereof for those years. See Davis v. Commissioner,
supra at 41; Tornichio v. Commissioner, supra.2
We also agree with Appeals Officer Sansbury that the closing
letter concerns the proposed additions to income and related
adjustments for 1996, not the assessments based upon petitioner’s
self-determined tax liability for that year. The close proximity
in time between (1) petitioner’s March 13, 1998, fax of the
2 There is no explanation in the record of the discrepancy
between the $69,234 credited by respondent to petitioner’s
account for 1990-94 and the $69,336 alleged by petitioner (on the
basis of the trustee’s final report, which is not in evidence) to
have been “paid to the IRS for taxes.” The $102 difference is
inconsequential, and if that additional amount was paid to the
IRS for a year other than 1990-94, it was not 1996, the year in
issue.
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