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requirements prerequisite to collection. Petitioners contend
that respondent used incorrect forms for the notice and demand
and otherwise failed to meet the requirements because of the lack
of personal verification by the Secretary or a person shown to be
authorized to exercise the Secretary’s authority.
At the Appeals hearing, petitioners were provided with a
transcript of their account, which detailed information
underlying the assessment of the tax in question. Petitioners do
not question whether all of the steps had been taken or
performed. In effect, they dispute the genuineness or
authenticity of the documents respondent used to meet the
statutory requirements.
Petitioners contend that the Form 4340 is insufficient to
prove the validity of the assessment that was made against them
for their 1998 tax year. Form 4340 has been generally accepted
by courts to show that a valid assessment has been made within
the meaning of section 6203. Hefti v. IRS, 8 F.3d 1169 (7th Cir.
1993); Farr v. United States, 990 F.2d 451, 454 (9th Cir. 1993);
Geiselman v. United States, 961 F.2d 1 (1st Cir. 1992); Davis v.
Commissioner, supra. Petitioners have raised superficial
questions and made conclusory allegations regarding the
assessment (such as whether respondent used the proper form), but
they have shown no actual irregularity in the assessment process.
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