- 12 - petitioners’ receipt of the refund check is insufficient to show that their outstanding tax liabilities are paid in full. Respondent presented as evidence certified copies of Forms 4340, Certificate of Assessments, Payments and Other Specified Matters, with respect to 1992, 1993, and 1996 to show that petitioners’ tax liabilities were properly assessed and that the amounts remained outstanding as of September 29, 2003. A Form 4340 satisfies the verification requirements of section 6330(c)(1). See Burke v. Commissioner, 124 T.C. 189, 195-196 (2005). Petitioners have not alleged any irregularity in the assessment procedure that would raise a question about the validity of the assessment or the information contained in the Forms 4340. Petitioners did not submit an offer-in-compromise or offer a collection alternative to the Appeals Office. At trial, petitioners’ counsel requested that petitioners be allowed an opportunity to enter into an installment agreement. Respondent asserts that AO Cleveland raised the possibility of an installment agreement during the conference. Petitioners, however, apparently declined to entertain collection alternatives because they wanted respondent to issue a notice of determination to allow them to come before the Court. The Court does not find that a remand is necessary or would be productive. See Lunsford v. Commissioner, 117 T.C. 183, 188-Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 NextLast modified: November 10, 2007