What is the test for establishing that the government has properly assessed the amount of income tax owed to a taxpayer?
MultiRegion, United States of America
The following excerpt is from U.S. v. Odd, 95 F.3d 1160 (9th Cir. 1996):
The Government submitted Certificates of Assessments and Payments (Forms 4340) showing that the assessments were properly made. Taxpayers have not produced sufficient evidence to establish that their tax liability is any different than that shown on Forms 4340. "[I]n the absence of contrary evidence, [Forms 4340] are sufficient to establish that notices and assessments were properly made." Hughes v. United States, 953 F.2d 531, 540 (9th Cir.1992).
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