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of discretion for an Appeals officer to rely on Form 4340, Nestor
v. Commissioner, supra at 166; Davis v. Commissioner, supra at
41, or a computer transcript of account, Schroeder v.
Commissioner, T.C. Memo. 2002-190; Mann v. Commissioner, T.C.
Memo. 2002-48, to comply with section 6330(c)(1).
Here, the record contains Forms 4340 for 1998 and 1999,
indicating that assessments were made for each of these years and
that taxes remain unpaid. Although the Form 4340 for 1999
contains one labeling error explained by respondent in the notice
of determination, the error does not affect the existence of
valid, unsatisfied assessments.3 Petitioner has cited no further
irregularities that would cast doubt on the pertinent liability
information recorded the Forms 4340.
In addition to the specific dictates of section 6330, the
Secretary, upon request, is directed to furnish to the taxpayer a
copy of pertinent parts of the record of assessment setting forth
the taxpayer’s name, the date of assessment, the character of the
liability assessed, the taxable period, if applicable, and the
amounts assessed. Sec. 6203; sec. 301.6203-1, Proced. & Admin.
3 The assessment of income tax for 1999 was inadvertently
labeled as an “agreed audit deficiency prior to 30 or 60 day
letter”, as opposed to an “audit deficiency per default to 90 day
letter”. Nonetheless, other entries on the form clarify the
factual circumstances, and in any event the issue was adequately
considered and addressed by the Appeals officer in determining
whether the collection action should be sustained (an observation
unaffected by a typographical error in the notice of
determination referring to the 1999 year as 1990).
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