Sam E. Scott - Page 19




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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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