Arcediano v. United States

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• explaining that burden is on taxpayer to present evidence to rebut “presumptive proof of a valid assessment” set out in Certificates of Assessment (internal quotation marks omitted)
• interpreting rule 56(f) of the Federal Rules of Civil Procedure
• “[t]he IRS satisfies its obligation to mail a notice of deficiency if the notice is sent to the taxpayer’s last known address, even if the taxpayer does not actually receive the notice”
• if a taxpayer does not present evidence to the contrary, a district court may properly rely on the Forms 4340 to conclude that valid assessments were made
• “If a taxpayer does not present evidence indicating to the contrary, a district court may properly rely on the [Forms 4340] to conclude that valid assessments were made.”
• “The IRS satisfies its obligation to mail a notice of deficiency if the notice is sent to the taxpayer's last known address, even if the taxpayer does not actually receive the notice

Source: CourtListener parenthetical corpus (CC0).