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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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