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 withPage: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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