Tenth Circuit· 7/21/1992

Guthrie v. Sawyer

Citations

970 F.2d 733
23 Fed. R. Serv. 3d 645
70 A.F.T.R.2d (RIA) 5390
1992 U.S. App. LEXIS 16313
1992 WL 166317

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).

Judges: Ebel, McKay, Seymour

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Cited by

55 cases in this archive cite this case; the 20 most cited are listed.

Cites

15 cases in this archive are cited by this case.

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