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
Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011