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ers have not shown any irregularity in respondent’s assessment
procedures that raises a question about the validity of respon-
dent’s assessments of those tax liabilities.
On the record before us, we find that respondent did not
abuse respondent’s discretion in determining to proceed with
collection of petitioners’ respective tax liabilities for taxable
years 1993 through 1996.
We have considered all of petitioners’ contentions and
arguments on brief that are not discussed herein with respect to
their position that respondent’s assessments of their respective
tax liabilities for taxable years 1993 through 1996 are invalid
because one of respondent’s assessment officers did not sign and
date Forms 4340 that respondent prepared with respect to those
years, and we find them to be irrelevant and/or without merit.7
6(...continued)
and (2) for taxable years 1995 and 1996. Petitioners have not
shown, or even alleged, that one of respondent’s assessment
officers did not sign and date those Forms 23C.
7We shall address one matter that, while not altogether
clear, petitioners may be arguing on brief. Petitioners may be
taking the position on brief that the July 16, 1999 notices of
Federal tax lien are invalid and unenforceable because they did
not receive certain documentation to which they are entitled
under sec. 6203. That section states that a taxpayer is entitled
to a copy of the “record of the assessment”. The regulations
under sec. 6203 provide:
If the taxpayer requests a copy of the record of as-
sessment, he shall be furnished a copy of the pertinent
parts of the assessment which set forth the name of the
taxpayer, the date of assessment, the character of the
(continued...)
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