- 20 -
Commissioner, 119 T.C. 252, 262 (2002); Nestor v. Commissioner,
118 T.C. at 166.
A Form 4340, 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 a Form 4340 for each of the years
at issue, indicating that assessments were made for the year and
that taxes remain unpaid. Petitioner has failed to cite any
irregularities with respect to the Forms 4340 introduced into
evidence 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
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