upholding use of IRS transcripts for purposes of complying with the verification requirement until the taxpayer provides evidence of irregularity in assessment process
How later courts described this case
- upholding use of IRS transcripts for purposes of complying with the verification requirement until the taxpayer provides evidence of irregularity in assessment process
- holding, without explicit consideration of section 7521(a)(1
- "[T]here may be cases, where taxpayers were not given a proper opportunity for an Appeals hearing, where it will be appropriate for this Court to require that an Appeals hearing be held. However, we do not believe that this should be done where, as in this case, the only arguments that petitioners presented to this Court were based on legal propositions which we have previously rejected."
- “A certified transcript (Form 4340) reflecting an assessment is presumptive proof of the taxpayer’s (continued...
Written by the judges who cited it.
The opinion
HALPERN, J., concurring: I concur with the result reached by the majority. In my concurring report in Lunsford v. Commissioner, 117 T.C. 159, 169 (2001), I have offered some comments concerning our authority to dictate to respondent the nature of the hearing required by section 6330(b). I incorporate those comments herein by this reference.
Whalen, Beghe, and Thornton, JJ., agree with this concurring opinion.