Nicklaus v. Comm'r
United States Tax Court
HELD: Sec. 301.6203-1, Proced. & Admin. Regs., does not require that one of respondent's assessment officers sign and date Form 4340, Certificate of Assessments and Payments, in order to have a valid assessment of a taxpayer's liability. HELD, FURTHER: Forms 4340 that respondent prepared with respect to petitioners' respective tax liabilities for taxable years 1993 through 1996 indicate that respondent properly assessed those liabilities.
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HELD: Sec. 301.6203-1, Proced. & Admin. Regs., does not require that one of respondent's assessment officers sign and date Form 4340, Certificate of Assessments and Payments, in order to have a valid assessment of a taxpayer's liability. HELD, FURTHER: Forms 4340 that respondent prepared with respect to petitioners' respective tax liabilities for taxable years 1993 through 1996 indicate that respondent properly assessed those liabilities. HELD, FURTHER: Respondent did not abuse respondent's discretion in determining to proceed with collection of petitioners' respective tax liabilities for…
1Opinion of the Court
OPINION
CHIECHI, Judge:
The petition in this case was filed in response to a “Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330” (notice of determination).
Background
The record establishes and/or the parties do not dispute the following.
At the time the petition in this case was filed, petitioners’ mailing address was in Stevenson, Washington.
On September 12, 1995, petitioners filed their Federal income tax return (return) for 1993, and on September 19, 1995, petitioners filed their return for 1994. On January 28, 1998, pursuant to section 6020(b)1 respondent…
2Cases cited9 opinions
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3Cited by108 opinions
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