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procedures had been met, which is not an abuse of discretion.
The record now contains Form 4340 for taxable year 2000, which
indicates that an assessment was made for 2000 and that taxes
remain unpaid. Petitioner has cited no irregularities that would
cast doubt on the pertinent liability information recorded on
Form 4340.
In addition to the specific dictates of section 6330, the
Secretary, upon request, is directed to furnish to the taxpayer a
copy of pertinent parts of the record of assessment setting forth
the taxpayer’s name, the date of assessment, the character of the
liability assessed, the taxable period, if applicable, and the
amounts assessed. Sec. 6203; sec. 301.6203-1, Proced. & Admin.
Regs. A taxpayer receiving a copy of Form 4340 has been provided
with all the documentation to which he or she is entitled under
section 6203 and section 301.6203-1, Proced. & Admin. Regs.
Roberts v. Commissioner, supra at 370 n.7. This Court has
likewise upheld collection actions where taxpayers were provided
with literal transcripts of account (so-called MFTRAX). See
Frank v. Commissioner, T.C. Memo. 2003-88; Swann v. Commissioner,
T.C. Memo. 2003-70. Ms. Derrick mailed to petitioner literal
transcripts prior to the telephonic hearing, and petitioner was
provided with Form 4340 subsequent to the telephonic hearing and
issuance of the notice of determination, but prior to trial.
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Last modified: November 10, 2007