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Respondent assessed tax, penalties, and interest for
petitioners’ 1993-96 tax years and sent them a notice of balance
due for those years. Id. at 117-118. Prior to November 25,
1998, petitioners received a notice from respondent that
respondent intended to collect tax owed by petitioners for those
years by levy. Id. at 118. On November 25, 1998, respondent
issued a notice of levy to two banks with respect to petitioners’
tax liabilities for 1993-95. Id.
Respondent filed notices of Federal tax lien with respect to
petitioners’ 1993-96 tax years on July 16, 1999. Id. at 118.
Petitioners timely requested a hearing. Id. Respondent’s
Appeals Office conducted the hearing and gave petitioners copies
of Forms 4340, Certificate of Assessments and Payments, for 1993-
96. Id. at 119. After the hearing, respondent issued a notice
of determination sustaining the notice of Federal tax lien. Id.
at 119-120.
Petitioners timely filed a petition with this Court to
obtain judicial review of respondent’s notice of determination
relating to the lien. A trial was held. On brief, petitioners
said that the sole issue was whether the requirements for issuing
a Form 4340 had been met. Id. at 120. In our opinion in that
case, we held that the requirements for sustaining the notice of
Federal tax lien had been met because Form 4340 establishes a
presumption that tax was validly assessed, and petitioners had
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