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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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Last modified: November 10, 2007