Stan D. Kaye - Page 8




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          underlying the assessments of the tax in question.  However,                
          petitioner does not question whether all of the steps had been              
          taken or performed.  Instead, he argues that documents used by              
          respondent to provide petitioner with notice were not genuine or            
          authentic, and accordingly, do not meet the statutory                       
          requirements.                                                               
               Petitioner contends that the Form 4340 is insufficient to              
          prove that proper notice was given and that the assessments were            
          valid.  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.  Petitioner has raised superficial questions and made                
          conclusory allegations regarding the assessment (such as whether            
          respondent used the proper form), but he has not shown any                  
          substantive or meaningful irregularity in the assessment process.           
          See Nicklaus v. Commissioner, 117 T.C. 117, 121 (2001); Berkey v.           
          IRS, 88 AFTR 2d 2001-6530, 2001-2 USTC par. 50,708 (E.D. Mich.              
          2001).                                                                      
               Petitioner also complains that he did not receive a notice             
          and demand.  This contention, however, is similar to the others             
          made by petitioner; i.e., he does not question whether he                   
          actually received various documents from respondent, but he                 






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