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(retroactive to April 26, 1993) as a payment “processed in error”
(consistent with respondent’s return of the property to
petitioner in 1998). Petitioner alleges no irregularity in these
transcripts that would raise a question about the information
contained therein. Moreover, the record contains a copy of the
notice of deficiency issued to petitioner with respect to his
1990 taxes and shows that as part of his verification process the
Appeals officer appropriately considered the District Court’s
finding in McIntosh v. United States, 82 AFTR 2d 98-6501, at 98-
6510, that the notice of deficiency for 1990 was timely issued to
petitioner at his last known address.
The record also contains three copies of Form 4340,
Certificate of Assessments and Payments, of petitioner’s 1990
account dated April 16, 1996, May 29, 1998, and October 4, 2002.
Petitioner received these Forms 4340 at various times before and
after his Appeals Office hearing. Such certificates of
assessments and payments “are generally regarded as being
sufficient proof, in the absence of evidence to the contrary, of
the adequacy and propriety of notices and assessments that have
been made.” Gentry v. United States, 962 F.2d 555, 557 (6th Cir.
1992); see Schroeder v. Commissioner, T.C. Memo. 2002-190;
Kaeckell v. Commissioner, T.C. Memo. 2002-114. Petitioner
contends that various circumstances show that the Forms 4340 lack
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