Dale Kinslow - Page 7

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          issues not otherwise raised in these assignments of error are               
          deemed conceded.  Id.                                                       
               In his underlying petition, petitioner made no such                    
          assignments of error with respect to respondent’s determination.            
          The petition only contained statements that petitioner objected             
          to the determination on the basis that the Federal tax system was           
          both voluntary and inherently unfair.  Accordingly, pursuant to             
          Rule 331(b)(4), the Court holds that petitioner conceded all                
          other issues relevant to the notice of determination.                       
               We finally consider whether respondent has verified,                   
          pursuant to section 6330(c)(1), that all of the requirements of             
          applicable law or administrative procedure were satisfied with              
          respect to the CDP action.  The underlying record contains the              
          declaration of Monty Luhmann (Mr. Luhmann), a settlement officer            
          with respondent’s Office of Appeals, in which Mr. Luhmann                   
          attested to the underlying tax and penalty assessments made                 
          against petitioner for the years 1997, 1998, and 1999.  Mr.                 
          Luhmann’s attestation was based upon his review of respondent’s             
          transcripts generated by its Integrated Data Retrieval System.              
          These transcripts contain petitioner’s name, Social Security                
          number, the amounts assessed, and gross and taxable income.  The            
          Court has held that the use of records containing such                      
          information by an Appeals officer is not an abuse of discretion             
          when used to verify an assessment.  Kuglin v. Commissioner, T.C.            






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