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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.
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Last modified: November 10, 2007