- 10 -
imposed therein. See Roberts v. Commissioner, 118 T.C. 365, 371
n.10, and cases cited thereat; Standifird v. Commissioner, T.C.
Memo. 2002-245, affd. 72 Fed. Appx. 729 (9th Cir. 2003); Weishan
v. Commissioner, T.C. Memo. 2002-88. In this regard we note that
the transcript provided all the information prescribed in section
301.6203-1, Proced. & Admin. Regs. See Weishan v. Commissioner,
supra; Lindsey v. Commissioner, T.C. Memo. 2002-87, affd. 56 Fed.
Appx. 802 (9th Cir. 2003).3
Petitioner has not raised any irregularity in the assessment
procedure that would raise a legitimate question about the
validity of the assessment or the information contained in the
transcript and the Form 4340. Accordingly, we conclude that the
Appeals officer here satisfied the verification requirement of
section 6330(c)(1).
Notice and Demand
We similarly reject petitioner’s argument that he never
received a notice and demand for payment of his unpaid tax
liability for 1997. The Form 4340 shows that respondent sent
3 As indicated above, the Appeals officer provided
petitioner at his Appeals hearing with the literal transcript of
his account that she reviewed. Sec. 6330(c)(1) does not even
require an Appeals officer, at or prior to a collection due
process hearing, to give the taxpayer a copy of the verification
that the requirements of any applicable law or administrative
procedure have been met. Sec. 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. Nestor v. Commissioner, 118 T.C. 162, 166-167
(2002).
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