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respondent’s use in respondent’s assessment procedure of RACS
006, instead of Form 23C, to make an assessment with respect to
petitioner’s taxable year 1996 does not comply with the require-
ments of section 6203 and section 301.6203-1, Proced. & Admin.
Regs.9
On the record before us, we find that respondent’s use of
RACS 006, instead of Form 23C, in making an assessment with
respect to petitioner’s taxable year 1996 did not constitute an
irregularity in respondent’s assessment procedure. On that
record, we agree with respondent’s position in respondent’s
motion, and we find: (1) There was no irregularity in respon-
dent’s assessment procedure with respect to petitioner’s taxable
year 1996, (2) respondent made a valid assessment with respect to
that year, and (3) for purposes of complying with section
6330(c)(1), it was not an abuse of discretion for the Appeals
officer to have relied on Form 4340 to verify respondent’s
assessment with respect to that year, see Davis v. Commissioner,
9We also reject petitioner’s apparent attempt to dictate how
respondent implements the requirements of sec. 6203 and sec.
301.6203-1, Proced. & Admin. Regs. In this connection, peti-
tioner stated in petitioner’s December 21, 1998 request to the
IRS Disclosure Office:
Please provide a copy of the actual, duly signed and
certified, Form 23-C, Certificate of Assessments, as
per 26 CFR 301.6203-1 * * * (Do not send a RACS Report
or an Individual Master File, as these are not respon-
sive to this request). * * * [Emphasis added.]
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