- 4 - 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 9/25/00Page: Previous 1 2 3 4 5 6 7 8 Next
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