Brian and Tina Nicklaus - Page 12

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          D.   Whether Requirements for Collection of Petitioners’ Tax                
               Liabilities Have Been Met                                              
               1.   Errors on Form 4340                                               
               An assessment is made by recording the tax liability in the            
          office of the Secretary in accordance with rules or regulations             
          prescribed by the Secretary.  Sec. 6203.  A Form 4340, absent               
          evidence to the contrary, is sufficient to establish that the               
          assessment was properly made.  United States v. Zolla, 724 F.2d             
          808, 810 (9th Cir. 1984); Psaty v. United States, 442 F.2d 1154,            
          1159 (3d Cir. 1971); Nicklaus v. Commissioner, supra at 121.                
               Treasury regulations require that the summary record,                  
          through supporting records, identify the taxpayer.  Sec.                    
          301.6203-1, Proced. & Admin. Regs.  Petitioners point out that              
          respondent misspelled petitioner’s first name and used an                   
          incorrect Social Security number for Tina Nicklaus on the Forms             
          4340 for 1995 and 1996.  Petitioners contend that the errors show           
          that the Forms 4340 are unreliable, and thus the requirements for           
          collection of their tax liabilities for the years in issue have             
          not been met.  We disagree.                                                 
               The Forms 4340 for 1995 and 1996 pertain only to the tax               
          liability of petitioner.  Respondent correctly stated                       
          petitioner’s middle initial, last name, and Social Security                 
          number on those Forms 4340.  The erroneous Social Security number           
          for petitioner’s spouse on the Forms 4340 for 1995 and 1996 does            
          not affect this case because:  (1) Respondent seeks to collect by           

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