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capricious, or without sound basis in fact or law. Woodral v.
Commissioner, 112 T.C. 19, 23 (1999).
Petitioners contend that the determinations generating these
cases evince an abuse of discretion on three principal grounds:
(1) Failure to satisfy the verification requirement of section
6330(c)(3)(A); (2) failure to address or properly to evaluate all
issues raised by petitioners per the mandate of section
6330(c)(3)(B); and (3) failure properly to weigh intrusion per
section 6330(c)(3)(C). Respondent disagrees with each claim.
Section 6330(c)(3)(A) incorporates a directive that the
determination take into consideration the section 6330(c)(1)
“verification from the Secretary that the requirements of any
applicable law or administrative procedure have been met.” The
referenced requirements are not further illuminated by statute or
regulation. The Court has repeatedly rejected challenges based
on this provision where the Appeals officer had secured formal or
informal transcripts showing both that the subject taxes were
properly assessed and that the taxpayer had been notified of
those assessments through issuance of notices of balance due.
Burke v. Commissioner, 124 T.C. 189, 194-195 (2005); Roberts v.
Commissioner, 118 T.C. at 371 n.10; Nestor v. Commissioner, 118
T.C. at 166; Lunsford v. Commissioner, 117 T.C. 183, 188 (2001).
Mr. Skidmore did so here.
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