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Discussion
All of the arguments that petitioners have presented in this
case, in one form or another, have been rejected in prior cases.
Those arguments dealing with the taxability of their income are
irrelevant in any event. Because they received the statutory
notice of deficiency for 1996, 1997, and 1998, petitioners were
not entitled to challenge their underlying tax liability at the
hearing conducted under section 6330. Sec. 6330(c)(2)(B). They
did not raise any bona fide issues or collection alternatives at
the hearing, and they have not raised any genuine issues in this
case. There was no abuse of discretion with respect to the
determination that collection should proceed.
Numerous cases establish that no particular form of
verification is required, that no particular document need be
provided to taxpayers at a hearing conducted under section 6330,
and that Form 4340 provided to the taxpayers after the hearing
satisfies the requirements of section 6330(c)(1). See, e.g.,
Roberts v. Commissioner, supra; Nestor v. Commissioner, 118 T.C.
162, 167 (2002); Hauck v. Commissioner, supra; Kuglin v.
Commissioner, T.C. Memo. 2002-51. Scores of cases have disposed
of claims indistinguishable from petitioners’ claims by summary
judgment, with imposition of a penalty under section 6673. See,
e.g., Roberts v. Commissioner, supra; Hill v. Commissioner, T.C.
Memo. 2003-144; Holguin v. Commissioner, T.C. Memo. 2003-125;
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