Robert E. Crandall - Page 16

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          challenge his underlying liability under the rationale of                   
          Montgomery v. Commissioner, 122 T.C. 1, 9 (2004),5 he has at no             
          time offered even a scintilla of evidence that would show error             
          in respondent’s determinations.  Since he did not address                   
          computation of his 1998 tax liability either at trial or on                 
          brief, even a de novo review would not avail petitioner.                    
          Moreover, he has now forfeited his chance to suggest any                    
          meritorious issues worthy of remand.                                        
                    3.  Review for Abuse of Discretion                                
               Petitioner has also made various arguments relating to                 
          aspects of the assessment and collection procedures that we                 
          review for abuse of discretion.  Action constitutes an abuse of             
          discretion under this standard where arbitrary, capricious, or              
          without sound basis in fact or law.  Woodral v. Commissioner, 112           
          T.C. 19, 23 (1999).                                                         
               Federal tax assessments are formally recorded on a record of           
          assessment in accordance with section 6203.  The Commissioner is            
          not required to use Form 23C in making an assessment.  Roberts v.           
          Commissioner, 118 T.C. at 369-371.  Furthermore, section                    
          6330(c)(1) mandates neither that the Appeals officer rely on a              
          particular document in satisfying the verification requirement              
          nor that the Appeals officer actually give the taxpayer a copy of           
          the verification upon which he or she relied.  Craig v.                     

               5 Cf. Farley v. Commissioner, T.C. Memo. 2004-168.                     

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