instant case, the loss of the administrative file gives rise to the possibility that the penalty assessment in question lacks foundation. As described in Janis and its progeny, however, an assessment is not “naked” simply because the administrative file supporting its entry is lost — what is critical, given the de novo nature of the proceedings before this court, is that admissible evidence exists to support the assessment. See Estate of Magnin v. Commissioner, 184 F.3d 1074, 1081 (9th Cir.1999); Karme v. Commissioner, 673 F.2d 1062, 1065 (9th Cir.1982). If such evidence exists, and is admitted by the court, it is irrelevant whether it is the same evidence that the Service relied upon in originally making its assessment. See Coleman v. United States, 704 F.2d 326, 329 (6th Cir.1983) (<HOLDING>). Indeed, consistent with the “no-look”
holding that agency decisions enjoy a presumption of correctness holding evidence insufficient to overcome presumption of correctness holding that because there was no factual dispute between the parties the presumption of correctness is not relevant holding that although the presumption of correctness applies to the ultimate classification decision  the presumption carries no force as to questions of law holding that assessment was naked but noting that secondhand records or any demonstrably reasonable methodology of estimation may be used to establish presumption of correctness