- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10
Last modified: May 25, 2011