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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