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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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