James Dwain & Jill R. Haws - Page 14

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          sustain the Appeals Office determination that the proposed levy             
          should proceed.                                                             
          D.  Verification Requirement                                                
               Under section 6330(c)(1), the Appeals officer is required to           
          investigate and verify that the requirements of any applicable              
          law or administrative procedure have been met.  Section                     
          6330(c)(1) does not require the Commissioner to rely on a                   
          particular document to satisfy the verification requirement                 
          contained therein, and the Appeals officer may generally rely on            
          transcripts of account, see McIntosh v. Commissioner, T.C. Memo.            
          2003-279, or Forms 4340, see Lunsford v. Commissioner, 117 T.C.             
          183, 187-188 (2001), to satisfy the verification requirement.               
          See also Kuglin v. Commissioner, T.C. Memo. 2002-51.  If the                
          transcripts of account or Forms 4340 reveal irregularities,                 
          however, further investigation is required.  See, e.g., Huff v.             
          United States, 10 F.3d 1440, 1446 (9th Cir. 1993); Lunsford v.              
          Commissioner, supra.                                                        
               Settlement Officer Stefanski relied solely on transcripts              
          of account to verify that the requirements of any applicable law            
          or administrative procedure have been met.  These transcripts               
          showed that an installment agreement was approved on April 3,               
          2001, for petitioners’ 1992, 1993, and 1994 tax liabilities.                
          Although Settlement Officer Stefanski acknowledged that the 1992            
          tax liability was included in the installment agreement, he                 






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