Thomas W. Roberts - Page 8




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               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.                                                       





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