In Hefti v. IRS, the Seventh Circuit explained that "Certificates of Assessments and Payments establish the fact of assessment and carry with them a presumption of validity and that the assessments they reflect were properly made." Hefti v. IRS, 8 F.3d 1169, 1172 (7th Cir. 1993) (citations omitted). "Certificates of Assessments and Payments provide a sufficient basis for establishing that the assessments at issue were duly made without requiring discovery of the underlying source documents".

As the district court correctly concluded, IRS Form 4340 supplies all of the information that Miller is entitled to under the statute and regulation. See Hefti v. IRS, 8 F.3d 1169, 1172 (7th Cir. 1993); Ford v. Pryor, 552 F.3d 1174, 1178 (10th Cir. 2008); Roberts v. Comm'r, 329 F.3d 1224, 1228 (11th Cir. 2003). Moreover, as the district court also correctly ruled, Miller did not need those forms to oppose summary judgment because courts do not look behind the assessment to evaluate the underlying evidence unless the taxpayer submits evidence to show the assessment is "without rational foundation," which Miller did not provide.

"Certificates of Assessments and Payments establish the fact of assessment and carry with them a presumption of validity and that the assessments they reflect were properly made." Hefti v. Internal Revenue Serv., 8 F.3d 1169, 1172 (7th Cir. 1993); see also United States v. Maier, No. 17 C 08433, 2019 WL 1399983, at *6 (N.D. Ill. Mar. 28, 2019) ("The IRS records its assessments on Forms 4340, which 'establish the fact of assessment and carry with them a presumption of validity and that the assessments they reflect were properly made.'" (quoting Hefti, 8 F.3d at 1172)); United States v. Ritland, No. 15 C 1062, 2017 WL 25468, at *2 (E.D. Wis. Jan. 3, 2017) ("The IRS uses Form 4340, the certificate of assessments, payments, and other specified matters, to assist in its calculation.

We review a district court's grant of summary judgment de novo. See Adler Drobny, Ltd. v. United States, 9 F.3d 627, 629 (7th Cir. 1993); Hefti v. Internal Revenue Serv., 8 F.3d 1169, 1171 (7th Cir. 1993). Summary judgment is proper when "the pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law."

In view of the plain language of these provisions, it is settled that unless the taxpayer has first filed a proper claim with the Internal Revenue Service, a court lacks subject matter jurisdiction over a suit for refund. United States v. Felt Tarrant Mfg. Co., 283 U.S. 269, 272, 51 S.Ct. 376, 377 (1931); see also, e.g., Hefti v. IRS, 8 F.3d 1169, 1173 (7th Cir. 1993) (citing Goulding v. United States, 929 F.2d 329, 331 (7th Cir. 1991), cert. denied, 506 U.S. 865, 113 S.Ct. 188 (1992)); Martin v. United States, 833 F.2d 655, 658-59 (7th Cir. 1987). As we recognized in Hefti, the requirements reflected in section 7422(a) and the regulations promulgated pursuant to that statutory provision serve several purposes:

We review the district court's decision on this legal question de novo. Hefti v. I.R.S., 8 F.3d 1169, 1171 (7th Cir. 1993). This case comes to us on a grant of summary judgment, which procedural posture would ordinarily require us to consider the facts in the light most favorable to the non-moving party.

As the party seeking summary judgment based on the statute of repose, Honeywell bears the initial burden of identifying evidence tending to show that its valve was installed in the Averys' furnace more than ten years before the explosion. See generally Hefti v. Internal Revenue Service, 8 F.3d 1169, 1171 (7th Cir. 1993) (citing Celotex Corp. v. Catrett, 477 U.S. 317, 322, 323, 106 S.Ct. 2548, 2552, 2553, 91 L.Ed.2d 265 (1986)). Once Honeywell has met this burden, however, the Averys are obligated to come forward with evidence sufficient to establish a genuine factual dispute as to when the valve was installed.

” See Hefti v. IRS, 8 F.3d 1169, 1172 (7th Cir. 1993); see also United States v. Braithwaite, 2017 WL 2793801, at *2 (N.D. Ill. 2017) (“[I]t is well established in tax law that an assessment is entitled to a presumption of legal correctness.”) (citing Fior D'Italia, Inc., 536 U.S. at 242); Gen. Star Indemn. Co. v. Hubbard Bowling Lanes, Inc., 2003 WL 22048740, at *2 (N.D. Ill. 2003)

The purposes of the treasury regulations and the refund claim requirement are to: (1) "ensure that the IRS has been given adequate notice of the nature of the claim and the specific facts upon which it is predicated, permitting administrative review and determination," (2) "give the IRS an opportunity to correct any errors that may have been made," and (3) "limit the scope of refund litigation." Hefti v. IRS, 8 F.3d 1169, 1173 (7th Cir. 1993). Treasury Regulation section 301.6402-2(b)(1) provides:

A properly supported and specific refund claim allows the IRS to investigate a taxpayer's claims, make any necessary corrections, and reach a decision on its merits without resorting to litigation. Hefti v. Internal Revenue Service, 8 F.3d 1169, 1173 (7th Cir. 1993); Ottawa Silica Co. v. United States, 699 F.2d 1124, 1138 (Fed. Cir. 1983). If the taxpayer's claims cannot be resolved at the administrative level, these regulations further protect the IRS by limiting the scope of litigation to those issues which it has already examined and indicated that it is willing to litigate.