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 isPage: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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