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all relevant information requested by Appeals,
including financial statements, for its consideration
of the facts and issues involved in the hearing.
The Appeals officer relied on a Form 4340, Certificate of
Assessment and Payments, to verify the proper assessments of the
taxes in issue. Generally, courts have held that Form 4340
provides at least presumptive evidence that a tax has been
validly assessed under section 6203. See Farr v. United States,
990 F.2d 451, 454 (9th Cir. 1993); Geiselman v. United States,
961 F.2d 1, 5-6 (1st Cir. 1992); Rocovich v. United States, 933
F.2d 991, 994 (Fed. Cir. 1991); United States v. Chila, 871 F.2d
1015, 1017-18 (11th Cir. 1989); United States v. Miller, 318 F.2d
637, 638-39 (7th Cir. 1963). Petitioner’s argument that the
production of, and reliance by the Appeals officer on, a Form
4340 to establish a procedurally proper assessment is an abuse of
discretion or irregularity is without legal support. See Davis
v. Commissioner, 115 T.C. 35 (2000). "Certificates of Assessments
and Payments are routinely used to prove that tax assessment has
in fact been made. They are presumptive proof of a valid
assessment." Guthrie v. Sawyer, 970 F.2d 733, 737 (10th Cir.
1992) (quotation marks and citations omitted). Petitioner has
neither averred nor demonstrated any irregularity in the
assessment procedure that would raise a question as to the
validity of the assessment. We therefore hold it was not an
abuse of discretion for Appeals to rely, in part, on a Form 4340
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