- 22 - remarkable than that, after an assessment of tax is made, record of that assessment is posted to the IRS’ computerized record system. Davis v. Commissioner, T.C. Memo. 2007-201. Ms. Osborn’s theory that assessment predating posting indicates something fraudulent was rejected by the court in Dahmer v. United States, 90 AFTR 2d 2002-6804, 2002-2 USTC par. 50,806 (W.D. Mo. 2002), in a ruling that accepted the Government’s position that the Dahmers’ evidence that the June 25, 1993[,] assessment was entered into the IRS administrative computer records in October 1993 provided no evidence of fraud because an assessment occurs on the date an authorized official signs a summary record of assessment containing the taxpayer’s assessment rather than the date the assessment is posted to the IRS computerized record system. * * * Indeed, petitioners neglect even to discuss Ms. Osborn or her “cycle post date” theory in their written responses to our orders to show cause, which suggests to us that they no longer attach any value to her testimony or theory. See Nicklaus v. Commissioner, 117 T.C. 117, 120 n.4 (2001) (concluding that taxpayers abandoned arguments and contentions asserted prior to the filing of their brief where they failed to advance those arguments and contentions on brief). We see no merit in the affirmative defense. Petitioners’ inability to show the merit of any averment, claim, or argument advanced by them leads us to the conclusion that they initiated and have maintained these proceedingsPage: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 NextLast modified: November 10, 2007