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the assessment”, sec. 301.6203-1, Proced. & Admin. Regs.).
Kuglin v. Commissioner, T.C. Memo. 2002-51.
Petitioner further contends that he was not provided with
the record of assessment. Where the Commissioner provides the
taxpayer with Forms 4340 (i.e., proof of assessment) before
trial, and the taxpayer does not “show at trial any irregularity
in the assessment procedure that would raise a question about the
validity of the assessments”, the taxpayer is not prejudiced.
Nestor v. Commissioner, 118 T.C. 163, 167 (2002). Prior to
trial, petitioner received copies of the Forms 4340 relating to
the years in issue. At trial, petitioner did not show any
irregularity in the assessment procedure. Accordingly, we
sustain the respondent’s determination.
Contentions we have not addressed are irrelevant, moot, or
meritless.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011