James Vernon Williams - Page 16

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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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