Raymond and Cynthia Turner-Simmons - Page 9

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          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.                               




























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