Richard N. Pate - Page 6




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          requirements of any applicable law or administrative procedure              
          have been met.”  Explaining this provision, the legislative                 
          history states:  “the IRS is required to verify that all                    
          statutory, regulatory, and administrative requirements for the              
          proposed collection action have been met.”  H. Conf. Rept. 105-             
          599, at 264 (1998), 1998-3 C.B. 747, 1018 (emphasis added); see             
          Greene-Thapedi v. Commissioner, 126 T.C. 1, 6 (2006).  Consistent           
          with this explanation, this and other Courts have repeatedly and            
          consistently construed the verification requirement to be met               
          where the Appeals officer secured formal or informal transcripts            
          showing that the taxes were properly assessed and that the                  
          taxpayer had been properly notified of those assessments.  See              
          Cox v. Commissioner, 126 T.C. 237, 255 (2006) (and cases cited              
          therein); see also Jones v. Commissioner, 338 F.3d 463 (5th Cir.            
          2003) (the verification requirement was satisfied where an                  
          Appeals officer referred to a Form 4340, Certificate of                     
          Assessments, Payments, and Other Specified Matters, to determine            
          that the IRS had followed legal and administrative procedures);             
          Roberts v. Commissioner, 329 F.3d 1224, 1228 (11th Cir. 2003)               
          (Form 4340 provides prima facie evidence that the IRS has                   
          complied with its statutory duties), affg. 118 T.C. 365 (2002).             
          In particular, it has been repeatedly held that the requirements            
          of all applicable laws and administrative procedures were met as            






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