Plaintiffs demand a complete record of how the Notes were handled and their whereabouts, and conclude that “[t]his court retains the capacity and is the only venue to grant the relief sought by [Plaintiffs.” Id. c. The Government’s Reply. The Government replies that, although Plaintiffs’ Response challenges the validity of the Notice of Deficiency and the Certificate of Assessment and Payment for the years at issue, Plaintiffs have presented no evidence that the IRS did not assess taxes in the amount stated on the 1996-1999 Certificates. Gov’t Resp. at 2. A Certificate of Assessment and Payment is “presumed to be correct, and is prima facie evidence that the IRS made the assessments reflected in the Certificate.” Id. (citing Rocovich v. United States, 933 F.2d 991, 994 (Fed.Cir.1991) (<HOLDING>)); see also Rohmann v. United States, 25 Cl.Ct.
holding claim that an assessment is made in violation of section 193155 is an action to contest an assessment and is governed by section 1941712 holding that a court would abuse its discretion by relying on a clearly erroneous assessment of the evidence holding that a certificate of assessment and payment is presumptive proof of a valid assessment by the irs holding that full payment of the assessment is also required for tax refund suits brought in the united states court of federal claims holding that form 4340 showing notice of assessment and demand for payment is admissible under the federal rules of evidence