Crevenne C. and Barbara A. Carrillo - Page 24

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          Assessment, with copies of the tax returns from which the                   
          assessments emanated, and with verification from the Secretary              
          that the requirements of any applicable law or administrative               
          procedure were met.                                                         
               Federal tax assessments are formally recorded on a record of           
          assessment in accordance with section 6203.  The Commissioner is            
          not required to use Form 23C in making an assessment.  Roberts v.           
          Commissioner, 118 T.C. at 369-371.  Furthermore, section                    
          6330(c)(1) mandates neither that the Appeals officer rely on a              
          particular document in satisfying the verification requirement              
          nor that the Appeals officer actually give the taxpayer a copy of           
          the verification upon which he or she relied.  Craig v.                     
          Commissioner, supra at 262; Nestor v. Commissioner, supra at 166.           
               A Form 4340, Certificate of Assessments, Payments and Other            
          Specified Matters, for instance, constitutes presumptive evidence           
          that a tax has been validly assessed pursuant to section 6203.              
          Davis v. Commissioner, 115 T.C. at 40 (and cases cited thereat).            
          Consequently, absent a showing by the taxpayer of some                      
          irregularity in the assessment procedure that would raise a                 
          question about the validity of the assessments, a Form 4340                 
          reflecting that tax liabilities were assessed and remain unpaid             
          is sufficient to support collection action under section 6330.              
          Id. at 40-41.  We have specifically held that it is not an abuse            
          of discretion for an Appeals officer to rely on Form 4340, Nestor           






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