- 8 - As we understand petitioner’s position, he is arguing that, because respondent used a computer and RACS 006, instead of Form 23C, to make an assessment with respect to petitioner’s taxable year 1996, he has shown an irregularity in respondent’s assess- ment procedure with respect to that year. That is because, according to petitioner, respondent’s failure to use Form 23C to make an assessment with respect to petitioner’s taxable year 1996 means that there was no signed summary record of assessment, as required by section 6203 and section 301.6203-1, Proced. & Admin. Regs.,6 and consequently no assessment, or at least no valid 5(...continued) in the January 5, 1999 Disclosure Office letter: “In your case however, there have been no assessments other than the processing of your tax return plus penalty and interest.” We reject peti- tioner’s unfounded reading of that sentence. The sentence in question plainly indicates that respondent assessed the tax due shown in petitioner’s return for 1996 as well as a penalty and interest with respect to that year. 6Sec. 6203 provides, inter alia, that an assessment is to be made by recording the liability of the taxpayer in accordance with prescribed rules or regulations. Sec. 301.6203-1, Proced. & Admin. Regs., provides in pertinent part: The assessment shall be made by an assessment officer signing the summary record of assessment. The summary record, through supporting records, shall provide identification of the taxpayer, the character of the liability assessed, the taxable period, if applicable, and the amount of the assessment. * * * If the taxpayer requests a copy of the record of assessment, he shall be furnished a copy of the pertinent parts of the assessment which set forth the name of the taxpayer, the date of assessment, the character of the liability assessed, the taxable period, if applicable, and the amounts assessed.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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