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of the proposed levy action. Sec. 6330(c)(3). The determination
of the Appeals officer under section 6330, except a determination
regarding the underlying tax liability that is made pursuant to
section 6330(c)(2)(B), is reviewed for abuse of discretion. Sego
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. Ms. Chadwell, 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
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