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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 repeatedly
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Last modified: May 25, 2011