Lunsford v. Commissioner of Internal Revenue
United States Tax Court
117 T.C. 159 (2001)
Facts
Joseph and Wanda Lunsford (plaintiffs) owed the Internal Revenue Service (IRS) (defendant) for unpaid taxes. The IRS sent the Lunsfords a notice of intent to levy as part of its collection effort. The Lunsfords petitioned the IRS for a collections due-process hearing. In their petition, the Lunsfords challenged the validity of the process the IRS had used in making the assessment supporting the levy. The IRS sent the Lunsfords a notice of determination sustaining the IRS’s levy. The Lunsfords then filed a petition in the United States Tax Court challenging the determination. The trial judge made an inquiry about whether, under the Tax Court’s jurisprudence, the Lunsfords’ allegation of deficient process regarding the IRS’s assessment raised an issue as to the Tax Court’s jurisdiction over the Lunsfords’ petition.
Rule of Law
Issue
Holding and Reasoning (Ruwe, J.)
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