-9-
Petitioners have failed to raise any arguments which have
not been previously rejected by this Court.2 Thus,
notwithstanding petitioners’ request to have a “meaningful
hearing” under sections 6320 and 6330, we consider it neither
necessary or productive to remand this case to Appeals to hold a
hearing. Lunsford v. Commissioner, 117 T.C. 183 (2001). We
sustain respondent’s notice of a lien filing and respondent’s
determination as to the proposed levy as a permissible exercise
of discretion.
We have considered all arguments and have found those
arguments not discussed herein to be irrelevant and/or without
merit. To reflect the foregoing,
Decision will be entered
for respondent.
2 We also note that the Form 4340 received by petitioners is
a valid verification that the requirements of any applicable law
or administrative procedure have been met and is sufficient for
the purposes of complying with the requirements of sec.
6330(c)(1). Roberts v. Commissioner, 118 T.C. 365 (2002).
Petitioners have not demonstrated in this proceeding any
irregularity in the assessment procedure that would raise a
question about the validity of the assessment or the information
contained in Form 4340. See Mann v. Commissioner, T.C. Memo.
2002-48.
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