W. James Kubon - Page 10

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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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