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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 a
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