Charles G. and Daphne C. M. Hall - Page 9




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          Goza v. Commissioner, supra.  As the Court of Appeals for the               
          Fifth Circuit has remarked:  “We perceive no need to refute these           
          arguments with somber reasoning and copious citation of                     
          precedent; to do so might suggest that these arguments have some            
          colorable merit.”  Crain v. Commissioner, 737 F.2d 1417, 1417               
          (5th Cir. 1984).  Suffice it to say that petitioners are                    
          taxpayers subject to the Federal income tax, see secs. 1(a)(1),             
          7701(a)(1), (14), and that compensation for labor or services               
          rendered constitutes income subject to the Federal income tax,              
          sec. 61(a)(1); United States v. Romero, 640 F.2d 1014, 1016 (9th            
          Cir. 1981).                                                                 
               We likewise reject petitioners’ argument 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 by section 6330(c)(1).  The record shows               
          that the Appeals officer obtained and reviewed a Form 4340 with             
          regard to petitioners’ taxable year 1998.                                   
               Federal tax assessments are formally recorded on a record of           
          assessment.  Sec. 6203.  “The summary record, through supporting            
          records, shall 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.                                                      








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