Joseph D. and Wanda S. Lunsford v. Commissioner

117 T.C. No. 16

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. In their request Ps questioned whether there was a valid summary record of the assessment of the taxes in issue. 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…