Case: Legal Presumption of Correctness Afforded IRS’s Assessments Not Overcome (3d Cir.) (IRC §6201)

Government’s tax assessments have legal presumption of correctness that a taxpayer failed to prove otherwise, the Third Circuit Court of Appeals held in affirming the district court’s granting the government summary judgment. Despite receiving proper notice and demand, Taxpayer failed to pay his income tax liability. Taxpayer failed to overcome the legal presumption of correctness of the IRS’s tax assessments for the 2010, 2014, and 2015 tax year, the court held. The court stated that Taxpayer did not offer any evidence to dispute the IRS’s assessment for the 2014 or 2015 tax years and his claim that his 2010 tax ...