- 19 - specific indication by petitioner as to the information or documents he was or was not provided either prior to or during the hearing process. The Appeals officer used Forms 4340 to verify the assessments. We have held that “it was not an abuse of discretion for the Appeals officer to use Forms 4340 for purposes of complying with section 6330(c)(1).” Nestor v. Commissioner, 118 T.C. 162, 166 (2002); Davis v. Commissioner, supra at 41; Lindsay v. Commissioner, T.C. Memo. 2001-285. Section 6330(c)(1) does not require the Appeals officer to provide taxpayers with a copy of a document verifying that the requirements of any applicable law or administrative procedure have been met. Section 301.6330-1(e)(1), Proced. & Admin. Regs., requires that the Appeals officer obtain verification before issuing the determination; it does not state that he or she must provide it to the taxpayer. Further, there is no legal requirement that the Appeals officer provide a taxpayer with copies of the delegations of authority, assessment records, or other underlying documents maintained by respondent with respect to a taxpayer’s account. Nestor v. Commissioner, supra at 166. Accordingly, the Appeals officer in this case sufficiently verified the 1991 tax assessments and was not required to provide more.Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 NextLast modified: November 10, 2007