Peter D. Dahlin Attorney at Law, P.S. - Page 13




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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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