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Duncan reviewed respondent’s administrative records for
petitioners and all documents submitted by petitioners. Duncan
considered petitioners’ arguments and concluded that petitioners
had not shown that there were any irregularities in assessment
procedures for the years in issue.
Respondent sent petitioners a Notice of Determination with
respect to the levy concerning their income tax liability for
1993 and 1994 on April 15, 2004. Respondent sent a Notice of
Determination to petitioner with respect to the levy concerning
income tax he owed for 1995-2000 on April 15, 2004. Petitioners
timely filed a petition in this Court.
On Forms 4340 for 1995 and 1996, Tina Nicklaus’s Social
Security number is partially incorrect and petitioner’s first
name is misspelled.
OPINION
A. Contentions of the Parties and Background
Petitioners contend that respondent’s transcripts show that
respondent did not follow proper assessment procedures and that
this Court lacked jurisdiction in their prior case before this
Court and in this case. Petitioners ask that we vacate the
decision in their prior case and that we remand this case to
respondent.1
1 Petitioners do not contend that sec. 7491(a) applies in
this case and have not established that they met the requirements
of sec. 7491(a)(2).
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