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those years were properly assessed, and that notice of the
assessments and demand for payment were properly made. Absent
some showing of irregularity, the Form 4340 provides presumptive
proof of its contents. Davis v. Commissioner, supra at 41. At
the hearing on respondent’s motion, petitioner husband alleged
several irregularities on the Forms 4340. We have examined these
allegations and find that they are either nonsensical,
contradicted by petitioners’ other admissions, immaterial, or
irrelevant to the collection action at issue. In sum, resolving
all factual inferences in petitioners’ favor, we find no
irregularity with respect to the assessment or collection action
at issue in this case which would cast doubt on the reliability
of the Forms 4340. Therefore, the Appeals officer’s conclusion
that all applicable laws and administrative requirements were met
was not an abuse of discretion.
C. Validity of the Assessments
Petitioners’ next allegation of error is that their 1996 and
1997 liabilities were not properly assessed. As support for this
claim, petitioners assert that the Appeals officer failed to
produce a copy of a “Record of Assessment” upon request.
Petitioners’ contention, even if true, is unavailing.
Section 6330(c)(1) requires only that the Appeals officer verify
that an assessment has been made; he need not provide such
verification to the taxpayer. Nestor v. Commissioner, 118 T.C.
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