- 7 - Petitioners’ Forms 4340, Certificate of Assessments, Payments, and Other Specified Matters, for 1995 and 1996, indicate that the notices of Federal tax liens were filed in November 2000, and April 2002, respectively. The Forms 4340 are sufficient proof, in the absence of evidence to the contrary, of the adequacy and propriety of notices and assessments that have been made. Orum v. Commissioner, supra. Further, respondent submitted copies of these notices, listing a certified mail number, the letter dates, and the date of filing. We also note that the address on the copies of the notices is “P.O. Box 1659, Loma Linda, CA 92354-1659.” This is the address the petitioners listed on their 1995 and 1996 tax returns, and petitioner testified that he has been receiving mail at this address since 1995. On the basis of the record, we find that the address used for the November 7, 2000, and April 24, 2002, notices was petitioners’ last known address. The only evidence that petitioners presented is petitioner’s testimony that they did not receive the notices. The Court need not accept at face value a witness’s testimony that is self- interested or otherwise questionable. See Archer v. Commissioner, 227 F.2d 270, 273 (5th Cir. 1955), affg. a Memorandum Opinion of this Court; Weiss v. Commissioner, 221 F.2d 152, 156 (8th Cir. 1955), affg. T.C. Memo. 1954-51; Schroeder v. Commissioner, T.C. Memo. 1986-467. Furthermore, petitionerPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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