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irregularities that would cast doubt on the information recorded
thereon.
In addition to the specific dictates of section 6330, the
Secretary, upon request, is directed to furnish to the taxpayer a
copy of pertinent parts of the record of assessment setting forth
the taxpayer’s name, the date of assessment, the character of the
liability assessed, the taxable period, if applicable, and the
amounts assessed. Sec. 6203; sec. 301.6203-1, Proced. & Admin.
Regs. A taxpayer receiving a copy of Form 4340 has been provided
with all the documentation to which he or she is entitled under
section 6203 and section 301.6203-1, Proced. & Admin. Regs.
Roberts v. Commissioner, supra at 370 n.7. This Court likewise
has upheld collection action where taxpayers were provided with
literal transcripts of account (so-called MFTRAX). See, e.g.,
Frank v. Commissioner, T.C. Memo. 2003-88; Swann v. Commissioner,
T.C. Memo. 2003-70. The November 19, 2002, letter to petitioner
from Mr. Tracy enclosed copies of transcripts of account for the
relevant years.
Furthermore, petitioner’s argument with regard to section
6204 is groundless. Section 6204(a) addresses supplemental
assessments and specifies: “The Secretary may, at any time
within the period prescribed for assessment, make a supplemental
assessment whenever it is ascertained that any assessment is
imperfect or incomplete in any material respect.” Section
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Last modified: May 25, 2011