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discretion or any meaningful procedural flaw attributable to any
failure of respondent’s representative to prove to petitioner
that they were authorized, we find that factor to be irrelevant.
See Nestor v. Commissioner, 118 T.C. 162, 166 (2002). This is
especially true in this case where petitioner’s arguments are
without substance and where he failed to present any meaningful
arguments or information bearing on the merits of the underlying
tax liability or respondent’s collection efforts.
Form 4340
Petitioner argues that under section 6330 he is entitled to
the underlying assessment documents and, ostensibly, that the
Form 4340 certification does not meet the statutory requirements.
The Appeals officer used Forms 4340, to verify the assessments.
We have held that “it was not an abuse of discretion for the
Appeals officer to use Forms 4340 for purposes of complying with
section 6330(c)(1).” Nestor v. Commissioner, supra at 166; see
also Davis v. Commissioner, 115 T.C. 35, 41 (2000); Lindsay v.
Commissioner, T.C. Memo. 2001-285, affd. 56 Fed. Appx. 800 (9th
Cir. 2003).
Section 6330(c)(1) does not require the Appeals officer to
provide taxpayers with a copy of a document verifying that the
requirements of any applicable law or administrative procedure
have been met. Section 301.6330-1(e)(1), Proced. & Admin. Regs.,
requires that the Appeals officer obtain verification before
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