Michael W. Bethea - Page 9

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          precluded under section 6330(c)(2)(B) from disputing his                    
          underlying tax liability in this proceeding.                                
               B.  Review for Abuse of Discretion                                     
               Petitioner also makes various arguments relating to aspects            
          of the assessment and collection procedures that we review for              
          abuse of discretion.  Petitioner claims that no valid assessment            
          supports the proposed levy and asserts that he should have been             
          provided with a copy of Form 23C, Summary Record of Assessment,             
          and with proof of the “filed return” from which the assessment              
          emanated.  Again, these arguments have been repudiated.                     
               Federal tax assessments are formally recorded on a record of           
          assessment in accordance with section 6203.  Upon request, the              
          Secretary is directed to furnish to the taxpayer a copy of                  
          pertinent parts of the record of assessment setting forth the               
          taxpayer’s name, the date of assessment, the character of the               
          liability assessed, the taxable period, if applicable, and the              
          amounts assessed.  Id.; sec. 301.6203-1, Proced. & Admin. Regs.             
          A Form 4340 constitutes presumptive evidence that a tax has been            
          validly assessed pursuant to section 6203.  Davis v.                        
          Commissioner, 115 T.C. 35, 40 (2000) (and cases cited thereat).             
               Absent a showing by the taxpayer of some irregularity in the           
          assessment procedure that would raise a question about the                  
          validity of the assessments, a Form 4340 reflecting that tax                
          liabilities were assessed and remain unpaid is sufficient to                






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