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v. Commissioner, supra at 610. Where the underlying tax
liability is properly at issue, the Court reviews any
determination regarding the underlying tax liability de novo.
Id.
A hearing officer may rely on a computer transcript or Form
4340, Certificate of Assessments, Payments and Other Specified
Matters, to verify that a valid assessment was made and that a
notice and demand for payment was sent to the taxpayer in
accordance with section 6303. Nestor v. Commissioner, 118 T.C.
162, 166 (2002). Absent a showing of irregularity, a transcript
that shows such information is sufficient to establish that the
procedural requirements of section 6330 have been met. Id. at
166-167.
In this case, the undisputed facts set forth in respondent’s
motion, declarations in support of the motion, and attached
exhibits establish that respondent has satisfied the requirements
of section 6330. Appeals Officer Stanton, who had had no prior
involvement with respect to the unpaid tax liabilities before the
section 6330 hearing as required by section 6330(b)(3), verified
that proper assessments were made as reflected on computer
transcripts attached to the motion for summary judgment and in
the notice of determination, and that the requisite notices had
been sent to the petitioners. Appeals Officer Stanton also
considered petitioners’ argument and rejected it as not relevant
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