-7-
genuine issue as to any material fact and that a decision may be
rendered as a matter of law.” Rule 121(a) and (b); Sundstrand
Corp. v. Commissioner, 98 T.C. 518, 520 (1992), affd. 17 F.3d 965
(7th Cir. 1994). The moving party bears the burden of proving
that there is no genuine issue of material fact, and factual
inferences are drawn in a manner most favorable to the party
opposing summary judgment. Dahlstrom v. Commissioner, 85 T.C.
812, 821 (1985); Jacklin v. Commissioner, 79 T.C. 340, 344
(1982).
Petitioners have raised no genuine issue as to any material
fact. Accordingly, we conclude that this case is ripe for
summary judgment.
Petitioners argue that respondent failed to make a valid
assessment of their tax liability because he did not issue to
them a Form 23C, Summary Record of Assessment. They assert that
an assessment could not have been made on the basis of their tax
return because “it shows no income taxes due and owing for 1997.”
We disagree with this argument. Federal tax assessments are
formally recorded on a record of assessment. Sec. 6203. The
summary record must “provide identification of the taxpayer, the
character of the liability assessed, the taxable period, if
applicable, and the amount of the assessment.” Sec. 301.6203-1,
Proced. & Admin. Regs. The transcript of account received by
petitioners before the Appeals Office hearing contained all this
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