Woodrow Reynolds - Page 10

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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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