The district director and the director of the regional service center shall appoint one or more assessment officers. The district director shall also appoint assessment officers in a Service Center servicing his district. The assessment shall be made by an assessment officer signing the summary record of assessment. The summary record, through supporting records, shall provide identification of the taxpayer, the character of the liability assessed, the taxable period, if applicable, and the amount of the assessment. The amount of the assessment shall, in the case of tax shown on a return by the taxpayer, be the amount so shown, and in all other cases the amount of the assessment shall be the amount shown on the supporting list or record. The date of the assessment is the date the summary record is signed by an assessment officer. If the taxpayer requests a copy of the record of assessment, he shall be furnished a copy of the pertinent parts of the assessment which set forth the name of the taxpayer, the date of assessment, the character of the liability assessed, the taxable period, if applicable, and the amounts assessed.
Notes of Decisions
March v. Internal Revenue Serv., 335 F.3d 1186 (10th Cir. 2003).
· cites it 6× “§ 6203 and 26 C.F.R. § 301.6203-1 , the IRS must provide a taxpayer, upon request, with an assessment of taxes due.”
Hibbs v. Winn, 542 U.S. 88 (2004).
· cites it 2× “" 26 CFR § 301.6203-1 (2003). [3] The term "assessment" is used in a variety of ways in tax law.”
Dallin v. United States, 62 Fed. Cl. 589 (Fed. Cl. 2004).
· cites it 7× “§ 6203 and its implementing regulation, 26 C.F.R. § 301.6203-1 (1990), such that the defendant was not permitted to include the section 6672 penalties for the subsequent quarters, the first three quarters of 1990, in that assessment.”
Ford v. Pryor, 552 F.3d 1174 (10th Cir. 2008).
· cites it 3× “§ 6203 (requiring the Treasury Secretary to “furnish the taxpayer a copy of the record of the assessment” upon request) and 26 C.F.R. § 301.6203-1 (setting forth the required contents of a summary record of assessment).”
Morrow v. United States, 723 F. Supp. 2d 71 (D.D.C. 2010).
· cites it 3× “§ 6203 and 26 C.F.R. § 301.6203-1 , by failing to record or sign the assessments, or furnish signed copies of the assessments to the plaintiff (Counts 14-17); and • 26 U.”
Thomas W. Roberts v. Comm'r of Internal Revenue, 329 F.3d 1224 (11th Cir. 2003).
· cites it 2× “Roberts claimed that: (1) the Commissioner did not provide him a copy of the record of assessment in his case, as required by 26 C.F.R. § 301.6203-1 , id. at 2 , (2) the Commissioner failed to claim that an assessment existed, id.”
Brewer v. United States, 764 F. Supp. 309 (S.D.N.Y. 1991).
· cites it 4× “However, there is no indication in the record before us that the “Summary Report of Assessments”, known as Form 23C, was completed and signed by the assessment officer as required by 26 C.F.R. § 301.6203-1 . 3 Nor do the Certificates of Assessments and Payments contain 23C dates…”
United States v. John A. Chila, 871 F.2d 1015 (11th Cir. 1989).
· cites it 2× “These documents equally satisfied the requirements of the regulation 26 C.F.R. § 301.6203-1 , which precisely track the language of the statute as to what is to be provided to the taxpayer by way of information.”
Maurice R. Huff, Nancy Huff v. United States, 10 F.3d 1440 (9th Cir. 1993).
· cites it 2× “In response, they claim to have received an indecipherable document entitled “IMF MCC TRANSCRIPT-SPECIFIC,” which did not contain the information required under 26 C.F.R. § 301.6203-1 . In June, 1991, the Huffs filed a complaint in federal district court.”
Burt Kroner v. Comm'r of Internal Revenue, 48 F.4th 1272 (11th Cir. 2022).
“§ 6203 ; 26 C.F.R. § 301.6203-1 . Kroner argues, and the Tax Court held, that an IRS supervi- sor must approve the initial determination of assessment before any penalty is communicated to the taxpayer.”
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