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tion with respect to petitioners’ taxable year 1998.4 On that
record, we sustain respondent’s determinations in that notice
with respect to petitioners’ taxable years 1999 through 2003.
We have considered all of the contentions and arguments of
the parties that are not discussed herein, and we find them to be
without merit, irrelevant, and/or moot.
To reflect the foregoing,
An appropriate order and
decision will be entered.
4We concluded above that the tax lien filing with respect to
petitioners’ taxable year 1998 was not proper.
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Last modified: November 10, 2007