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United States v. Hicks, 947 F.2d 1356, 1359 (9th Cir. 1991);
Wheeler v. Commissioner, 127 T.C. 200, 208 n.12 (2006).
Petitioner assigns as error respondent’s failure to provide
him various documents requested in his Form 12153 and
correspondence. Petitioner’s contention is without merit. There
is no right to discovery in the Appeals hearing, which is
informal. See Katz v. Commissioner, 115 T.C. 329, 337 (2000).
The Appeals officer did not abuse her discretion in declining to
provide the requested materials to petitioner. See Roberts v.
Commissioner, 118 T.C. 365, 372 (2002), affd. 329 F.3d 1224 (11th
Cir. 2003).
Petitioner suggests that respondent did not properly assess
his taxes for 2000 and 2001 because he did not receive requested
copies of Form 23C, Certificate of Assessment, or some other
summary record of assessment as required by section 6203 and
section 301.6203-1, Proced. & Admin. Regs. We reject
petitioner’s argument. Respondent was not required to use Form
23C in making the assessment. Roberts v. Commissioner, supra at
371. The Forms 4340, Certificate of Assessments, Payments, &
Other Specified Matters, which are in the record provide
presumptive evidence that respondent has validly assessed
petitioner’s 2000 and 2001 liabilities. Id. n.10. Furthermore,
on August 4, 2004, respondent issued to petitioner a notice of
tax lien, the last page of which set forth, among other things,
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