-6-
properly at issue. Sego v. Commissioner, 114 T.C. 604, 610
(2000).
Here, respondent notified petitioners that he was proposing
to levy upon their property in order to collect their Federal
income tax debt for 1998. Petitioners requested the hearing
referenced in section 6330, which was later held with Appeals.
Following the determination by Appeals that respondent’s proposed
levy was proper, petitioners sought relief in this Court.
Petitioners argue that the notices of determination were in error
because, they allege: (1) The assessment was not valid; (2) the
Appeals officer never received verification that the requirements
of applicable law and procedure had been met; (3) they never
received a “valid” notice of deficiency; and (4) they never
received a notice and demand for payment.
Summary judgment is intended to expedite litigation and
avoid unnecessary and expensive trials. Fla. Peach Corp. v.
Commissioner, 90 T.C. 678, 681 (1988). Summary judgment may be
granted with respect to all or any part of the legal issues in
controversy “if the pleadings, answers to interrogatories,
depositions, admissions, and any other acceptable materials,
together with the affidavits, if any, show that there is no
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
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