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and the following are among the facts, generally similar in each
attachment, on which the settlement officer relied: She had no
prior involvement with the taxes at issue; she had furnished
petitioners with copies of IRS Forms 4340, Certificate of
Assessments, Payments, and Other Specified Matters, which explain
and document the tax assessments for the years in issue;
petitioners had not presented any acceptable collection
alternatives, any financial information in order to consider
collection alternatives, and had not filed all required tax
returns; the proposed collection action balances the need for
efficient collection with petitioners’ concern that any
collection action be no more intrusive than necessary; and
applicable laws and administrative procedures were met. She
discusses in detail why the assessments of tax for 1996 and 1997
were timely. She also warns petitioners that they “should be
advised that unfounded allegations of procedural defects may be
construed as frivolous Collection Due Process appeals and may be
subject to monetary sanctions by the Tax Court under IRC Section
6673(a)(1).”
Petitions
On February 22, 2005, petitioners timely petitioned for
review of the notices. Each petition assigns error in
substantially the same terms. Except as noted, each (1) seeks to
challenge the tax liability underlying the collection actions at
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