117 T.C. No. 16
UNITED STATES TAX COURT
JOSEPH D. AND WANDA S. LUNSFORD, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18071-99L. Filed November 30, 2001.
R issued a notice of intent to levy, and Ps
requested a hearing before an IRS Appeals officer (A)
pursuant to sec. 6330, I.R.C. In their request Ps
questioned whether there was a valid summary record of
the assessment of the taxes in issue. A sent a letter
to Ps that enclosed a Form 4340, Certificate of
Assessments and Payments, showing that the assessments
were made and invited Ps to raise additional issues,
but Ps did not do so. A did not schedule a face-to-
face hearing. A issued a notice of determination, and
Ps timely petitioned the Tax Court for review.
Held: The Tax Court has jurisdiction under sec.
6330(d)(1)(A), I.R.C., based on a valid notice of
determination and a timely filed petition. In
determining the validity of the notice of determination
for jurisdictional purposes, we do not look behind the
notice to see whether Ps were afforded an appropriate
IRS Appeals hearing. The notice of determination sent
to Ps was valid on its face, and we have jurisdiction
to review the determination. Meyer v. Commissioner,
115 T.C. 417 (2000), is overruled to the extent it
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