Paul L. Bowman - Page 13

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               Even if the Court were to decline to consider the 2001                 
          notice of deficiency and the 2002 notice of deficiency attached             
          as exhibits to respondent’s motion, the declaration that was                
          signed by the settlement officer (settlement officer’s declara-             
          tion) and that was attached to that motion establishes that the             
          settlement officer considered whether a notice of deficiency was            
          issued to petitioner with respect to each of his taxable years              
          2001 and 2002 and determined that such a notice was issued for              
          each such year.  The settlement officer’s declaration states in             
          pertinent part:                                                             
               I verified through review of the Internal Revenue                      
               Service’s administrative file and IDRS [integrated data                
               retrieval system] information, including transcripts of                
               petitioner’s accounts,[8] copies of which are attached                 

               8With respect to the “transcripts of petitioner’s accounts”            
          to which the settlement officer referred in the settlement                  
          officer’s declaration, petitioner asserts:                                  
               the alleged ‘transcripts’ * * * are nothing but indeci-                
               pherable, computer coded gibberish.  If anyone is to                   
               make any sense of them, they must obviously be ‘de-                    
               coded’.  Respondent has presented absolutely nothing                   
               for ‘decoding’ its ‘transcripts’.  Moreover, there is                  
               nothing in the administrative record to indicate that                  
               any decoding actually took place, or, if any did take                  
               place, that it is correct.                                             
          We reject those assertions.  The respective “transcripts of                 
          petitioner’s accounts” with respect to petitioner’s taxable years           
          2001 and 2002 are coded computer-generated transcripts (coded               
          transcripts of account) that show certain information in the                
          official computer records of the Internal Revenue Service (IRS)             
          with respect to those years.  The respective Forms 4340 with                
          respect to petitioner’s taxable years 2001 and 2002 are noncoded            
          computer-generated transcripts that show certain information in             
          those same official computer records with respect to those years.           

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