Edward W. Clough - Page 9

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         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).                                                   

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