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received were not signed and therefore are in-
valid. You had an opportunity to respond to the
notices and be heard during the audit process.
Additionally, the notices provided you the oppor-
tunity to proceed to tax court if you disagreed
with the proposed liabilities. You have been
provided a certified transcript of your accounts
certifying the assessments. The Notices of Fed-
eral Tax Lien were filed in accordance with the
Internal Revenue Code. The Notices of Deficiency
were issued properly to you in accordance with the
Internal Revenue Code. The courts have found that
there is no Internal Revenue Code requirement that
the Notice of Deficiency be signed.
• It is Appeals decision that the Notices of Federal
Tax Lien were properly recorded and that the
recordation of the liens balances the need for
efficient collection of taxes with the taxpayer’s
legitimate concern that any collection action be
no more intrusive than necessary.
* * * * * * *
Summary of Determination:
It is Appeals decision that the Notices of Federal Tax
Lien were properly recorded.
Discussion
On brief, petitioners state: “The Petitioners in the case
at bar are only going to challenge, in this brief, the mandated
requirements of the Certificates of Assessments and Payments”,
i.e., Forms 4340, that the Appeals Office sent them with respect
to their taxable years 1993 through 1996.4
4On brief, petitioners advance none of the other arguments
and contentions that petitioners asserted prior to the filing of
their brief in this case. We conclude that petitioners have
abandoned those other arguments and contentions. See Rybak v.
Commissioner, 91 T.C. 524, 566 n.19 (1988). Even if we had not
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