- 9 - remaining liability--and even assuming that petitioners raised the issue of the adjustments in the Form 4549-CG at the section 6330 hearing--petitioners have failed to prove that Appeals erred in determining to proceed with collection of that liability. IV. Conclusion We sustain the determination. To reflect the foregoing, Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011