Debra L. Chase - Page 9




                                        - 9 -                                         
          might suggest that these arguments have some colorable merit.”              
          Crain v. Commissioner, 737 F.2d 1417, 1417 (5th Cir. 1984).                 
               Petitioner next contends that the Appeals officer failed to            
          obtain verification from the Secretary that the requirements of             
          all applicable laws and administrative procedures were met as               
          required under section 6330(c)(1).  We reject petitioner’s                  
          argument inasmuch as the record shows that the Appeals officer              
          obtained, reviewed and provided petitioner with copies of Forms             
          4340 with regard to petitioner’s account for 1995 and 1996.                 
               Federal tax assessments are formally recorded on a record of           
          assessment.  Sec. 6203.  The summary record of assessment,                  
          through supporting records, must “provide identification of the             
          taxpayer, the character of the liability assessed, the taxable              
          period, if applicable, and the amount of the assessment.”  Sec.             
          301.6203-1, Proced. & Admin. Regs.  We have held that Forms 4340            
          are presumptive evidence on which an Appeals officer may rely to            
          verify that an assessment was made against a person for purposes            
          of sections 6320 and 6330.  Davis v. Commissioner, 115 T.C. 35,             
          40-41 (2000); see Nestor v. Commissioner, 118 T.C. 162, 166-167             
          (2002).                                                                     
               Petitioner has not demonstrated any irregularity in the                
          assessment procedure that would raise a question about the                  
          validity of the assessments or the information contained in the             








Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  Next

Last modified: May 25, 2011