- 6 - 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 asPage: Previous 1 2 3 4 5 6 7 8 9 10 11 NextLast modified: November 10, 2007