Michael T. & Leone Carey - Page 11




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          validity of the assessment.  We conclude, as we did in Nestor v.            
          Commissioner, supra at 167, that petitioners have suffered no               
          prejudice by their receipt of the Form 4340 after the hearing.              
               Accordingly, for the reasons stated above, we sustain the              
          Commissioner’s proposed levy.  We have considered all arguments             
          made by petitioners, and those not discussed herein have been               
          rejected as without merit.                                                  
                                                  Decision will be entered            
                                             for respondent.                          
































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Last modified: May 25, 2011