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assessed. We pointed out that petitioner had not alleged any
specific irregularity in the assessment procedure and that an
Appeals officer may rely on a computer transcript or Form 4340,
Certificate of Assessments, Payments, and Other Specified
Matters, to verify that a valid assessment had been made. After
reviewing the computer transcripts of petitioner’s accounts,2
Appeals Officer Wong had concluded that “Assessments for all
years appear correct and based on established law, policy and
procedure.” We concluded in Kun I that the record contained “no
credible evidence to contradict Appeals Officer Wong’s
conclusion”, and we held that respondent had properly assessed
petitioner’s income tax liabilities. On September 21, 2004, we
entered our decision in accordance with our opinion in Kun I.
On October 15, 2004, petitioner’s motion to vacate or revise
opinion together with a memorandum of points and authorities and
2The parties stipulated to the admissibility of certified
copies of Forms 4340, Certificate of Assessments, Payments and
Other Specified Matters, with respect to petitioner’s accounts
for 1995-99. The Forms 4340 show that petitioner’s income tax
returns were filed and the tax liabilities shown thereon were
assessed on the following dates:
Year Date return filed Date tax assessed
1995 8/13/96 9/16/96
1996 8/18/97 9/15/97
1997 8/17/98 9/21/98
1998 8/16/99 9/20/99
1999 8/14/00 9/25/00
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