- 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.
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