- 7 - Commissioner, T.C. Memo. 2003-195. Petitioner’s arguments--in the hearing request, during the correspondence hearing, and at trial--were limited to the verification requirement in section 6330(c)(1). Petitioner’s presence was not required in order for respondent to verify whether the requirements of any applicable law or administrative procedure had been met. 3. Abuse of Discretion As noted supra, petitioner’s arguments regard the verification requirement in section 6330(c)(1). Petitioner contends that Appeals Officer Chambers did not verify that respondent (1) properly assessed the taxes for the years in issue and (2) issued petitioner notices of deficiency, notice and demand for payment, notice of intent to levy, and notice of his right to a hearing. Section 6330(c)(1) does not require the Commissioner to rely on a particular document to satisfy the verification requirement imposed therein. E.g., Schnitzler v. Commissioner, T.C. Memo. 2002-159. We have repeatedly held that the Commissioner may rely on Forms 4340 or transcripts of account to satisfy the verification requirement of section 6330(c)(1). Lindsey v. Commissioner, T.C. Memo. 2002-87, affd. 56 Fed. Appx. 802 (9th Cir. 2003); Tolotti v. Commissioner, T.C. Memo. 2002-86, affd. 70 Fed. Appx. 971 (9th Cir. 2003). Petitioner has not alleged any irregularity in the assessment procedure that would raise aPage: Previous 1 2 3 4 5 6 7 8 9 Next
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