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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