Lindsay
Lindsay v. Commissioner
Opinion
Lead Opinion
MEMORANDUM **
Terry L. Lindsay appeals pro se the Tax Court’s grant of summary judgment in favor of the Commissioner of Internal Revenue (“Commissioner”) in Lindsay’s action *801 challenging a federal tax lien. We have jurisdiction under 26 U.S.C. § 7482 . We review de novo, Gladden v. Commissioner, 262 F.3d 851, 853 (9th Cir.2001), and we affirm.
Lindsay contends that the Tax Court erred in granting summary judgment because the appeals officer who conducted his collection due process hearing did not provide him with Form 23C, a summary record of the assessments against him. We disagree. Lindsay was not entitled to receive Form 23C itself; he was entitled only to the pertinent information it contained. See Koff v. United States, 3 F.3d 1297, 1298 (9th Cir.1993) (per curiam) (“ ‘[i]f the taxpayer requests a copy of the record of assessment, he shall be furnished with a copy of the pertinent parts of the assessment which set forth the name of the taxpayer, the date of assessment, the character of the liability assessed, the taxable period, if applicable, and the amounts assessed’ ”) (quoting 26 C.F.R. § 301.6203-1 ). The record shows that Lindsay received all of the required…