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that the Appeals officer rely on a particular document in
satisfying the verification requirement nor that the Appeals
officer actually give the taxpayer a copy of the verification
upon which he or she relied. Craig v. Commissioner, 119 T.C.
252, 262 (2002); Nestor v. Commissioner, 118 T.C. 162, 166
(2002).
A Form 4340, for instance, constitutes presumptive evidence
that a tax has been validly assessed pursuant to section 6203.
Davis v. Commissioner, 115 T.C. 35, 40 (2000) (and cases cited
thereat). Consequently, absent a showing by the taxpayer of some
irregularity in the assessment procedure that would raise a
question about the validity of the assessments, a Form 4340
reflecting that tax liabilities were assessed and remain unpaid
is sufficient to support collection under section 6330. Id. at
40-41. This Court has specifically held that it is not an abuse
of discretion for an Appeals officer to rely on Form 4340 to
comply with section 6330(c)(1). Nestor v. Commissioner, supra;
Davis v. Commissioner, supra at 41. Similarly, it is not an
abuse of discretion for an Appeals officer to rely on a computer
transcript of account to comply with section 6330(c)(1).
Schroeder v. Commissioner, T.C. Memo. 2002-190; Mann v.
Commissioner, T.C. Memo. 2002-48.
Ms. Derrick relied on computer transcripts of petitioner’s
account in verifying that all applicable law and administrative
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