- 13 - 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. (continued...)Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 NextLast modified: November 10, 2007