117 T.C. No. 10
UNITED STATES TAX COURT
BRIAN AND TINA NICKLAUS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4221-00L. Filed September 14, 2001.
Held: Sec. 301.6203-1, Proced. & Admin. Regs.,
does not require that one of respondent’s assessment
officers sign and date Form 4340, Certificate of As-
sessments and Payments, in order to have a valid as-
sessment of a taxpayer’s liability.
Held, further: Forms 4340 that respondent pre-
pared with respect to petitioners’ respective tax
liabilities for taxable years 1993 through 1996 indi-
cate that respondent properly assessed those liabili-
ties.
Held, further: Respondent did not abuse respon-
dent’s discretion in determining to proceed with col-
lection of petitioners’ respective tax liabilities for
taxable years 1993 through 1996.
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