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liabilities for 1998 and 1999 in this collection review
proceeding. See Goza v. Commissioner, supra. In conjunction
with this point, we note that petitioner’s assertion that he did
not receive “valid” notices of deficiency is frivolous and
groundless. See, e.g., Nestor v. Commissioner, 118 T.C. 162, 166
(2002). As the Appeals Court for the Fifth Circuit has remarked:
“We perceive no need to refute these arguments with somber
reasoning and copious citation of precedent; to do so might
suggest that these arguments have some colorable merit.” Crain
v. Commissioner, 737 F.2d 1417 (5th Cir. 1984).
The record demonstrates that the Appeals Office properly
verified that all applicable laws and administrative procedures
were followed in this matter. It is well settled that section
6330(c)(1) does not require the Appeals Office to rely on a
particular form to satisfy the verification requirement, nor does
it require the Appeals Office to provide a taxpayer with a copy
of such verification. Roberts v. Commissioner, 118 T.C. 365 n.10
(2002), affd. 329 F.3d 1224 (11th Cir. 2003); Nestor v.
Commissioner, supra at 166. We have found that the Appeals
Office may verify an assessment by means of a transcript of
account such as the Forms 4340 attached to respondent’s motion.
Davis v. Commissioner, supra (Form 4340 is presumptive evidence
that an assessment was made against the taxpayer).
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