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An Appeals 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. Nestor v.
Commissioner, 118 T.C. 162, 166 (2002); Schaper v. Commissioner,
T.C. Memo. 2002-203; Schroeder v. Commissioner, T.C. Memo. 2002-
190. After reviewing the computer transcripts of petitioner’s
account, Appeals Officer Wong concluded that “Assessments for all
years appear correct and based on established law, policy and
procedure.” The record contains no credible evidence to
contradict Appeals Officer Wong’s conclusion. Accordingly, we
conclude that respondent properly assessed petitioner’s income
tax liabilities.
B. Petitioner’s Challenge to Respondent’s Determination To
Proceed With the Collection Action
1. Copies of Form 4340
Petitioner asserts that, at the hearing, Appeals Officer
Wong should have made available to petitioner a copy of Form
4340, Certificate of Assessments, for each of the taxable years
at issue and should have discussed the Forms 4340 with him. We
disagree. Although section 6203 provides that “Upon request of
the taxpayer, the Secretary shall furnish the taxpayer a copy of
the record of the assessment”, section 6330(c)(1) does not
require that the Appeals officer give to the taxpayer a copy of
the record of assessment at or before the hearing. See Nestor v.
Commissioner, supra at 166-167. Even if petitioner had requested
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Last modified: May 25, 2011