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3. Verification of Assessment Procedure
We conclude that Ms. Cahill obtained verification from the
Secretary that the requirements of all applicable laws and
administrative procedures were met as required by section
6330(c)(1). Ms. Cahill obtained and reviewed a TXMODA transcript
of account for petitioner’s 1999 taxable year before the
scheduled hearing.
Federal tax assessments are formally recorded on a record of
assessment. Sec. 6203. “The summary record, through supporting
records, shall provide identification of the taxpayer, the
character of the liability assessed, the taxable period, if
applicable, and the amount of the assessment.” Sec. 301.6203-1,
Proced. & Admin. Regs.
Section 6330(c)(1) does not require the Commissioner to rely
on a particular document to satisfy the verification requirement.
Roberts v. Commissioner, 118 T.C. 365, 371 n.10 (2002), affd. 329
F.3d 1224 (11th Cir. 2003); Kaeckell v. Commissioner, T.C. Memo.
2002-114. In this regard, the TXMODA transcript of account on
which Ms. Cahill relied contained all of the information
prescribed in section 301.6203-1, Proced. & Admin. Regs. See
Schroeder v. Commissioner, T.C. Memo. 2002-190; Weishan v.
Commissioner, T.C. Memo. 2002-88, affd. 66 Fed. Appx. 113 (7th
Cir. 2003); Lindsey v. Commissioner, T.C. Memo. 2002-87, affd. 56
Fed. Appx. 802 (9th Cir. 2003); Tolotti v. Commissioner, T.C.
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