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Where, as is the case here, the validity of the underlying
tax liability is not properly at issue, the Court will review the
administrative determination of the Commissioner of Internal
Revenue for abuse of discretion. Sego v. Commissioner, 114 T.C.
604, 610 (2000); Goza v. Commissioner, 114 T.C. 176, 182 (2000).
Petitioners state on brief, and we agree, that, in order for
the July 16, 1999 notices of Federal tax lien to be valid and
enforceable, the assessments that respondent made of petitioners’
respective tax liabilities for their taxable years 1993 through
1996 must have been valid. Petitioners argue that respondent’s
assessments of those liabilities were procedurally defective and
therefore not valid. That is because, according to petitioners,
one of respondent’s assessment officers did not sign and date
Forms 4340 that respondent prepared with respect to petitioners’
taxable years 1993 through 1996, respectively, as required by
section 301.6203-1, Proced. & Admin. Regs.
On the record before us, we reject petitioners’ position.
Section 301.6203-1, Proced. & Admin. Regs., does not require that
one of respondent’s assessment officers sign and date Form 4340
in order to have a valid assessment of a taxpayer’s liability.
Although those regulations do require an assessment to be made
4(...continued)
concluded that petitioners abandoned the arguments and conten-
tions which they advanced prior to the time that they filed their
brief in this case, on the record before us, we reject those
other arguments and contentions.
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