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3. Review for Abuse of Discretion
Petitioner has also made various arguments relating to
aspects of the assessment and collection procedures that we
review for abuse of discretion. Action constitutes an abuse of
discretion under this standard where arbitrary, capricious, or
without sound basis in fact or law. Woodral v. Commissioner, 112
T.C. 19, 23 (1999).
Federal tax assessments are formally recorded on a record of
assessment in accordance with section 6203. The Commissioner is
not required to use Form 23C in making an assessment. Roberts v.
Commissioner, 118 T.C. at 369-371. Furthermore, section
6330(c)(1) mandates neither that the Appeals officer rely on a
particular document in satisfying the verification requirement
nor that the Appeals officer actually give the taxpayer a copy of
the verification upon which he or she relied. Craig v.
Commissioner, 119 T.C. 252, 262 (2002); Nestor v. Commissioner,
118 T.C. at 166.
A Form 4340, Certificate of Assessments, Payments and Other
Specified Matters, 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
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