Paul L. Bowman - Page 16




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          IRS with respect to a stated taxpayer for a particular taxable              
          year regarding assessments, payments, and other specified matters           
          and (2) the respective dates on which such respective assessments           
          and payments were made and such other matters were undertaken.              
          That Form 4340 is generated on a stated date does not mean that             
          the information reflected in such form regarding assessments,               
          payments, and other specified matters did not appear in the                 
          official computer records of the IRS, or that such assessments,             
          payments, and other specified matters did not occur, before such            
          stated date.  The information that is shown in Form 4340 with               
          respect to each of petitioner’s taxable years 2001 and 2002 is              
          information that appeared in the official computer records of the           
          IRS on dates that preceded the date on which the settlement                 
          officer reviewed the administrative file and the information in             
          the IRS’s integrated data retrieval system relating to each such            
          year.  Such information pertained to assessments and payments               
          made and other specified matters undertaken on the dates speci-             
          fied in Form 4340 relating to each of petitioner’s taxable years            
          2001 and 2002, all of which dates preceded the date on which the            
          settlement officer made that review with respect to each of those           
          years.  We hold that neither Robinette v. Commissioner, supra,              
          nor any other authority precludes the Court’s consideration of              
          Form 4340 with respect to each of petitioner’s taxable years 2001           








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