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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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Last modified: May 25, 2011