-7-
(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 1998.
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 Form 4340 received by petitioners at
the Appeals Office hearing contained all this information.
Petitioners have not demonstrated in this proceeding any
irregularity in the assessment procedure that would raise a
question about the validity of the assessment or the information
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