Curtis J.L. McIntosh - Page 11

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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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