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Reddick v. Commissioner of Internal Revenue

United States Court of Appeals, Tenth Circuit

August 13, 2013

RON A. REDDICK, Petitioner-Appellant,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

(T.C. No. 22235-11L) (Tax Court)

Before HOLMES, HOLLOWAY, and BACHARACH, Circuit Judges.

ORDERAND JUDGMENT [*]

Jerome A. Holmes Circuit Judge

Ron A. Reddick has filed a petition for review of the Tax Court's decision sustaining the Commissioner of Internal Revenue's proposed levy to collect unpaid federal income tax liabilities, penalties, and interest from him for the 2006 tax year. Exercising jurisdiction under 26 U.S.C. § 7482(a)(1), we deny the petition for review and affirm the Tax Court.

For the reasons set forth in the Commissioner's response brief, Mr. Reddick's arguments challenging the Commissioner's tax assessments based on alleged defects related to the Form 4340 are without merit, see Aplee. Br. at 12-16, and they deserve no further comment given this court's decisions in Ford v. Pryor, 552 F.3d 1174, 1178-79 (10th Cir. 2008) (holding that a Form 4340 is presumptive proof of a valid assessment); March v. IRS, 335 F.3d 1186, 1187-89 (10th Cir. 2003) (same); Taylor v. IRS, 69 F.3d 411, 419 (10th Cir. 1995) (same); and Guthrie v. Sawyer, 970 F.2d 733, 737-38 (10th Cir. 1992) (same). Because Mr. Reddick failed to pay the income tax liability that he himself reported on his untimely 2006 tax returns, we also agree with the Commissioner that there was no requirement to issue a notice of deficiency before attempting to collect the late-filing penalty imposed under 26 U.S.C. § 6651(a)(1). See Aplee. Br. at 16-19. Finally, as pointed out by the Commissioner, ...


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