- 9 - in response to these notices of deficiency. Accordingly, petitioner cannot contest the underlying deficiencies for 1994 and 1996. Sec. 6330(c)(2)(B); Sego v. Commissioner, supra; Goza v. Commissioner, supra at 182-183. Claims that the limitation period for assessment has expired are challenges to the underlying tax liability. Boyd v. Commissioner, 117 T.C. 127, 130 (2001). Additionally, the assessments were timely made. Therefore, petitioner cannot raise these claims in this proceeding. Where the validity of the underlying tax liability is not properly in issue, we review the Commissioner’s determination for an abuse of discretion. Sego v. Commissioner, supra at 610. Petitioner appears to argue that the verification requirement of section 6330 has not been met. Section 6330(c)(1) does not require the Commissioner to rely on a particular document to satisfy the verification requirement imposed therein. E.g., Schnitzler v. Commissioner, T.C. Memo. 2002-159 (citing five other cases to support this principle). We have repeatedly held that the Commissioner may rely on Forms 4340, Certificate of Assessments, Payments, and Other Specified Matters, or transcripts of account to satisfy the verification requirement of section 6330(c)(1). Hromiko v. Commissioner, T.C. Memo. 2003- 107; Schnitzler v. Commissioner, supra; Kaeckell v. Commissioner, T.C. Memo. 2002-114; Obersteller v. Commissioner, T.C. Memo.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011