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deficient on it’s [sic] face because it is not in
compliance with 26 USC section 6065.
A face-to-face meeting was held between petitioners and an
Appeals officer on August 22, 2001. On November 5, 2001, the
Appeals officer issued a Notice of Determination Concerning
Collection Action(s) Under Section 6320 and/or 6330, wherein he
determined: (1) That the requirements of all laws and
administrative procedures had been met; (2) that petitioners had
had a prior opportunity to dispute the underlying tax liability
and were thus precluded from contesting it in the collection
proceeding; and (3) that no other issues had been raised. Based
on these findings, the Appeals officer determined that the lien
was appropriate.
On January 31, 2002, petitioners filed their petition in the
instant case. The petition raises several issues, including:
(1) Whether “procedurally proper” versions of various documents
were ever issued, including a notice of deficiency, a notice and
demand for payment, and a notice of Federal tax lien; (2) whether
petitioners’ liabilities were properly assessed; (3) whether the
Appeals officer failed to verify that the requirements of any
applicable law or administrative procedure were met, as required
by section 6330(c)(1); and (4) whether respondent erred by
failing to allow petitioners an examination interview and an
administrative appeal prior to issuance of the notice of
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