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deficiency for that year of $13,914, plus an addition to tax of
$3,478.50. Thus, while the letter of July 21, 1997, may have
been an accurate statement of petitioners’ 1991 liabilities
before the examination assessment, it obviously did not reflect
the deficiency to which they agreed in October 1997.
Accordingly, the letter provides no support for the claim that
petitioners’ 1991 liabilities were satisfied.
To the contrary, respondent has submitted a certified copy
of Form 4340, Certificate of Assessments, Payments, and Other
Specified Matters, for petitioners’ 1991 tax year. Absent some
showing of irregularity, which petitioners have not made, the
Form 4340 provides presumptive proof of its contents. See Hansen
v. United States, 7 F.3d 137, 138 (9th Cir. 1993); United States
v. Chila, 871 F.2d 1015, 1019 (11th Cir. 1989); Craig v.
Commissioner, 119 T.C. 252, 262-63 (2002); Davis v. Commissioner,
115 T.C. 35, 40-41 (2000). The Form 4340 indicates that six
payments of $400 each were made by petitioners during 1998 with
respect to their 1991 liabilities and does not indicate that any
further payments were made. The Form 4340 indicates that the
total amount of the examination assessment was $24,647.91. The
amount that respondent seeks to collect, $22,247.91, is $2,400
less than the amount of the examination assessment. The Form
4340 also indicates that the return assessment was abated shortly
after it was discharged. Accordingly, we conclude that all
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