Joseph D. and Wanda S. Lunsford - Page 1

                                   117 T.C. No. 17                                    

                               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.  The only issue that Ps                  
               raised in their request was whether there was a valid                  
               summary record of the assessments of the taxes in                      
               question.  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.  Ps timely petitioned the Tax Court for                 
               review.  The only substantive issue raised in the                      
               petition was whether the Form 4340 constituted                         
               sufficient verification of the assessments.                            
                    Held:  Our rules require petitioners to specify                   
               the basis upon which they seek relief.  Because the                    
               only substantive issue that petitioners raised in this                 
               judicial proceeding is whether A abused her discretion                 
               by relying on a Form 4340 to verify the assessments,                   
               and because we have previously decided in Davis v.                     
               Commissioner, 115 T.C. 35 (2000), that such reliance is                

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