- 16 - 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 2001Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 NextLast modified: November 10, 2007