Thomas Lou Harris - Page 4

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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             
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             for respondent.                          

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