- 15 -
than the Secretary) who signed the verification required under
section 6330(c)(1). Nestor v. Commissioner, supra at 166-167.
Section 6330(c)(1) does not require the Appeals officer to give
the taxpayer a copy of the verification that the requirements of
any applicable law or administrative procedure have been met.
Id. at 166.
An Appeals officer may use computer transcripts of account
for a taxpayer to verify that requirements of applicable law and
administrative procedure have been met. Keene v. Commissioner,
T.C. Memo. 2002-277 n.10; Hack v. Commissioner, T.C. Memo.
2002-243; Hauck v. Commissioner, T.C. Memo. 2002-184, affd. 64
Fed. Appx. 492 (6th Cir. 2003). Skidmore reviewed transcripts of
account for petitioner for 1998, 2001, and 2002, and concluded
that the requirements of applicable law and administrative
procedure had been met.
5. Whether Petitioner May Dispute Respondent’s Conclusion
Regarding His Tax Liability for 1998 in This Proceeding
Petitioner contends that he may dispute respondent’s
conclusion regarding his tax liability for 1998 in this
proceeding. We disagree. Petitioner gave the notice of
deficiency for 1998 to Kotmair; thus, it is clear that petitioner
had received it. A taxpayer may dispute respondent’s conclusion
regarding his or her tax liability at the section 6330 hearing if
he or she did not receive a notice of deficiency or otherwise
have an opportunity to dispute the tax liability. Sec.
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