Thomas W. Roberts - Page 1

                                   118 T.C. No. 23                                     

                               UNITED STATES TAX COURT                                 

                           THOMAS W. ROBERTS, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                       

               Docket No. 1991-01L.           Filed May 3, 2002.                       

                    R’s Appeals officer (A) issued a notice of deter-                  
               mination to P in which that officer determined to                       
               proceed with collection with respect to P’s taxable                     
               year 1996.  In making that determination, A relied on                   
               Form 4340, Certificate of Assessments, Payments, and                    
               Other Specified Matters (Form 4340).  A provided to P a                 
               copy of that form with the notice of determination but                  
               did not provide to him a copy of Form 23C, Assessment                   
               Certificate--Summary Record of Assessments (Form 23C).                  
               R has for a number of years been engaged in making a                    
               transition in R’s assessment procedure from the general                 
               use of a manually prepared Form 23C to the general use                  
               of a computer-generated Revenue Accounting Control                      
               System (RACS) Report 006 (RACS 006).                                    
                    Held:  R’s use of the computer-generated RACS 006,                 
               instead of the manually prepared Form 23C, in making an                 
               assessment with respect to P’s taxable year 1996 did                    
               not constitute an irregularity in R’s assessment proce-                 
               dure.  Held, further, R made a valid assessment with                    

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