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SECTION 6201. ASSESSMENT AUTHORITY

(a) AUTHORITY OF SECRETARY

The Secretary is authorized and required to make the inquiries,
determinations, and assessments of all taxes (including interest,
additional amounts, additions to the tax, and assessable penalties) imposed
by this title, or accruing under any former internal revenue law, which
have not been duly paid by stamp at the time and in the manner provided by
law. Such authority shall extend to and include the following:

(1) TAXES SHOWN ON RETURN

The Secretary shall assess all taxes determined by the taxpayer or by
the Secretary as to which returns or lists are made under this title.

(2) UNPAID TAXES PAYABLE BY STAMP

(A) OMITTED STAMPS

Whenever any article upon which a tax is required to be paid by
means of a stamp is sold or removed for sale or use by the
manufacturer thereof or whenever any transaction or act upon
which a tax is required to be paid by means of a stamp occurs
without the use of the proper stamp, it shall be the duty of the
Secretary, upon such information as he can obtain, to estimate
the amount of tax which has been omitted to be paid and to make
assessment therefor upon the person or persons the Secretary
determines to be liable for such tax.

(B) CHECK OR MONEY ORDER NOT DULY PAID

In any case in which a check or money order received under
authority of section 6311 as payment for stamps is not duly paid,
the unpaid amount may be immediately assessed as if it were a tax
imposed by this title, due at the time of such receipt, from the
person who tendered such check or money order.

(3) ERRONEOUS INCOME TAX PREPAYMENT CREDITS

If on any return or claim for refund of income taxes under subtitle A
there is an overstatement of the credit for income tax withheld at the
source, or of the amount paid as estimated income tax, the amount so
overstated which is allowed against the tax shown on the return or
which is allowed as a credit or refund may be assessed by the
Secretary in the same manner as in the case of a mathematical or
clerical error appearing upon the return, except that the provisions
of section 6213(b)(2) (relating to abatement of mathematical or
clerical error assessments) shall not apply with regard to any
assessment under this paragraph.

(b) AMOUNT NOT TO BE ASSESSED

(1) ESTIMATED INCOME TAX

No unpaid amount of estimated income tax required to be paid under
section 6654 or 6655 shall be assessed.

(2) FEDERAL UNEMPLOYMENT TAX

No unpaid amount of Federal unemployment tax for any calendar quarter
or other period of a calendar year, computed as provided in section
6157, shall be assessed.

(c) COMPENSATION OF CHILD

Any income tax under chapter 1 assessed against a child, to the extent
attributable to amounts includible in the gross income of the child, and
not of the parent, solely by reason of section 73(a), shall, if not paid by
the child, for all purposes be considered as having also been properly
assessed against the parent.

(d) REQUIRED REASONABLE VERIFICATION OF INFORMATION RETURNS.

In any court proceeding, if a taxpayer asserts a reasonable dispute with
respect to any item of income reported on an information return filed with
the Secretary under subpart B or C of part III of subchapter A of chapter
61 by a third party and the taxpayer has fully cooperated with the
Secretary (including providing, within a reasonable period of time, access
to and inspection of all witnesses, information, and documents within the
control of the taxpayer as reasonably requested by the Secretary), the
Secretary shall have the burden of producing reasonable and probative
information concerning such deficiency in addition to such information
return.

(e) DEFICIENCY PROCEEDINGS

FOR SPECIAL RULES APPLICABLE TO DEFICIENCIES OF INCOME, ESTATE, GIFT,
AND CERTAIN EXCISE TAXES, SEE SUBCHAPTER B.