- 9 - respondent for the years covered by the notice. We reject petitioner’s misguided reading of the notice and hold that respondent complied with all statutory requirements for a valid notice of deficiency.5 2. Assessment and Notice and Demand Petitioner argues that respondent failed to validly assess petitioner’s 1996-98 tax liabilities. Federal tax assessments are formally recorded on a summary record of assessment when they are made. Sec. 6203. The summary record must “provide identification of the taxpayer, the character of the liability assessed, the taxable period, if applicable, and the amount of the assessment.” Sec. 301.6203-1, Proced. & Admin. Regs. Section 6330(c)(1) does not require the Appeals Office to rely on a particular document to verify that it properly assessed the tax liabilities in question. See Roberts v. Commissioner, 118 T.C. 365, 371 n.10 (2002), affd. 329 F.3d 1224 (11th Cir. 2003); Kubon v. Commissioner, T.C. Memo. 2005-71. It is now well established that Appeals officers may rely on Form 4340,6 Certificate of Assessments, Payments, and Other Specified Matters, to verify 5 Because we find that petitioner received a valid notice of deficiency for 1996, 1997, and 1998, petitioner is precluded from contesting his underlying tax liability for 1996, 1997, and 1998. 6 Form 4340, Certificate of Assessments, Payments, and Other Specified Matters, constitutes a valid verification that the requirements of any applicable law or administrative procedure have been met under sec. 6330(c)(1). See Craig v. Commissioner, 119 T.C. 252, 262 (2002).Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 NextLast modified: November 10, 2007