James Vernon Williams - Page 17

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          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 Forms 4340 for 1999 and 2000,                
          indicating that assessments were made for each of these years and           
          that taxes remain unpaid.  Petitioner has cited no irregularities           
          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           
          copy of pertinent parts of the record of assessment setting forth           
          the taxpayer’s name, the date of assessment, the character of the           
          liability assessed, the taxable period, if applicable, and the              
          amounts assessed.  Sec. 6203; sec. 301.6203-1, Proced. & Admin.             
          Regs.  A taxpayer receiving a copy of Form 4340 has been provided           
          with all the documentation to which he or she is entitled under             
          section 6203 and section 301.6203-1, Proced. & Admin. Regs.                 
          Roberts v. Commissioner, supra at 370 n.7.  This Court likewise             
          has upheld collection action where taxpayers were provided with             
          literal transcripts of account (so-called MFTRAX).  See, e.g.,              

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