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During the consideration by the Appeals Office of petition-
ers’ objection to the July 16, 1999 notices of Federal tax lien,
the Appeals Office sent petitioners Form 4340, Certificate of
Assessments and Payments (Form 4340), with respect to each of
their taxable years 1993 through 1996. Form 4340 for each of the
years 1993 and 1994 showed, inter alia, that on August 24, 1998,
respondent had assessed on Form 23C petitioners’ tax liability
for each such year. Form 4340 for each of the years 1995 and
1996 showed, inter alia, that on August 31, 1998, respondent had
assessed on Form 23C petitioners’ tax liability for each such
year.
After the Appeals Office hearing was held regarding the July
16, 1999 notices of Federal tax lien, the Appeals Office issued a
notice of determination to petitioners on March 16, 2000. That
notice of determination stated in pertinent part as follows:
• All provisions of IRC �6330 and IRC �6320 have
been met. The Secretary has provided sufficient
verification that the requirements of applicable
law or administrative procedures have been met.
• Your Request for a Collection Due Process Hearing
was submitted under IRC �6320 to have the Notice
of Federal Tax Lien rescinded. In your request
for a hearing you alleged that you do not agree
with the notices or the amounts stated on these
notices and that you have not had an opportunity
to be heard and to present your facts to prove the
notices incorrect. You state that there is not an
assessment Form 23C in the record and that the
liens were filed without the mandated lawful pro-
cess of the Internal Revenue Code. You also state
that you have not been sent an official Notice of
Deficiency and that the Notices of Deficiency you
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Last modified: May 25, 2011