Cook v. United States

ORDER'

ALLEGRA, Judge.

Inextricably woven into the administration of the Federal tax laws is a fundamental promise that those laws will be enforced fairly and uniformly. Toward this end, the tax system includes a series of procedural protections for taxpayers associated with the assessment of taxes, penalties and interest. These procedures, however, constitute a double-edged sword for if the Internal Revenue Service (the “Service”) follows them and an assessment results, a set of judicially-created presumptions, grounded in the common law, arise to support the validity of the assessment. These…