Robert E. Crandall - Page 17

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          Commissioner, 119 T.C. 252, 262 (2002); Nestor v. Commissioner,             
          118 T.C. at 166.                                                            
               A Form 4340, Certificate of Assessments, Payments and Other            
          Specified Matters, for instance, constitutes presumptive evidence           
          that a tax has been validly assessed pursuant to section 6203.              
          Davis v. Commissioner, 115 T.C. at 40 (and cases cited thereat).            
          Consequently, absent a showing by the taxpayer of some                      
          irregularity in the assessment procedure that would raise a                 
          question about the validity of the assessments, a Form 4340                 
          reflecting that tax liabilities were assessed and remain unpaid             
          is sufficient to support collection action under section 6330.              
          Id. at 40-41.  We have specifically held that it is not an abuse            
          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.  Petitioner has cited no irregularities           
          that would cast doubt on the information recorded thereon.                  
               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           

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