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would like to point out that the courts have previously
ruled against your arguments, and in some instances,
have imposed sanctions. I am hopeful that you wish to
discuss legitimate issues and alternatives for resolv-
ing your case at the hearing.
On April 5, 2002, the settlement officer held an Appeals
Office hearing with petitioners with respect to the notice of
intent to levy relating to petitioners’ taxable year 1998 and the
notice of tax lien relating to their taxable years 1997 and 1998.
At the Appeals Office hearing, the settlement officer gave
petitioners, inter alia, Form 4340, Certificate of Assessments,
Payments, and Other Specified Matters, with respect to each of
their taxable years 1997 and 1998.
On May 16, 2002, the Appeals Office issued to Mr. Lyman a
notice of determination concerning collection action(s) under
section 6320 and/or 6330 (notice of determination) with respect
to the notice of intent to levy relating to taxable year 1998 and
issued to Ms. Lyman a separate notice of determination with
respect to that notice of intent to levy. On May 16, 2002, the
Appeals Office also issued to Mr. Lyman a notice of determination
with respect to the notice of tax lien relating to taxable years
1997 and 1998 and issued to Ms. Lyman a separate notice of
determination with respect to that notice of tax lien. An
attachment to each of those four notices of determination stated
in pertinent part:
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