Roberts v. Comm'r
United States Tax Court
R's Appeals officer (A) issued a notice of determination to P in which that officer determined to proceed with collection with respect to P's taxable year 1996. In making that determination, A relied on Form 4340, Certificate of Assessments, Payments, and Other Specified Matters (Form 4340). A provided to P a copy of that form with the notice of determination but did not provide to him a copy of Form 23C, Assessment Certificate -- Summary Record of Assessments (Form 23C). R…
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R's Appeals officer (A) issued a notice of determination to P in which that officer determined to proceed with collection with respect to P's taxable year 1996. In making that determination, A relied on Form 4340, Certificate of Assessments, Payments, and Other Specified Matters (Form 4340). A provided to P a copy of that form with the notice of determination but did not provide to him a copy of Form 23C, Assessment Certificate -- Summary Record of Assessments (Form 23C). R has for a number of years been engaged in making a transition in R's assessment procedure from the general use of a…
1Opinion of the Court
OPINION
Chiechi, Judge:
This case is before the Court on the parties’ cross-motions for partial summary judgment.1 We shall deny petitioner’s motion for partial summary judgment (petitioner’s motion), and we shall grant respondent’s motion for partial summary judgment (respondent’s motion).
Background
The record establishes and/or the parties do not dispute the following.
Petitioner resided in Winter Park, Florida, at the time he filed the petition in this case.
Petitioner filed a Federal income tax (tax) return (return) for his taxable year 1996, which showed $42,710 as the tax due for that year.…
2Cases cited10 opinions
- Goza v. CommissionerUnited States Tax Court · 2000
- Sego v. CommissionerUnited States Tax Court · 2000
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- Davis v. CommissionerUnited States Tax Court · 2000
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3Cited by91 opinions
- Craig v. Comm'rUnited States Tax Court · 2002
- Cox v. Comm'rUnited States Tax Court · 2006
- March v. Internal Revenue ServiceCourt of Appeals for the Tenth Circuit · 2003
- Burke v. Comm'rUnited States Tax Court · 2005
- Lindberg v. Comm'rUnited States Tax Court · 2010
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