- 10 - 6330(c)(1) only requires that the officer obtain such verification before making a determination; it does not require the officer to present a copy of the verification to the taxpayer. Nestor v. Commissioner, supra at 166-167. Nor does section 6330(c)(1) require the officer to rely on a particular document to satisfy the verification requirement imposed by that section. Craig v. Commissioner, supra at 261-262. The officer may rely on a Form 4340 to make such a verification because it “provides at least presumptive evidence that a tax has been validly assessed”. Davis v. Commissioner, 115 T.C. 35, 40 (2000). Petitioner actually received copies of the relevant Forms 4340 and has made no showing that would tend to call into question the accuracy of the information reported thereon. No abuse of discretion was committed with respect to the verification requirement. Petitioner did not show that there was any irregularity in the assessment procedure that would raise a question about the validity of the assessments. Respondent noted verification in the notice of determination that all requirements of applicable law and administrative procedure had been met and that respondent had properly balanced the need for efficient collection against any legitimate concerns of intrusiveness raised by petitioner. Petitioner has not presented any evidence or persuasive arguments that respondent abused his discretion but instead has repeatedlyPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011