Theodore W. Banis, Jr. - Page 11

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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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