- 10 -
To reflect the foregoing,
Decision will be entered
for respondent.
7(...continued)
liability assessed, the taxable period, if applicable,
and the amounts assessed. [Sec. 301.6203-1, Proced. &
Admin. Regs.]
The Court of Appeals for the Ninth Circuit, to which an appeal in
this case would normally lie, has held that respondent’s provid-
ing a taxpayer with a copy of Form 4340 satisfies the require-
ments of sec. 6203 and the regulations thereunder quoted above.
Koff v. United States, 3 F.3d 1297, 1298 (9th Cir. 1993).
Petitioners admitted through petitioner Brian Nicklaus’ testimony
that they received Forms 4340 that respondent prepared with
respect to their taxable years 1993 through 1996. We conclude
that petitioners received the documentation to which they are
entitled under sec. 6203 and sec. 301.6203-1, Proced. & Admin.
Regs.
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Last modified: May 25, 2011