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From U.S. v. Byock, a 3rd Circuit case, as reported by Tax Analysts:
The Byocks offered no evidence to suggest that the assessments were incorrect or to otherwise dispute the assessments... On appeal, as in the District Court, the Byocks do not dispute that they owe the back taxes. Instead, they focus solely on their belief that this complaint was filed as a personal vendetta and that the IRS made these assessments only after Matthew Byock reported an IRS employee to the District Director's Office. This allegation has no bearing on the Byocks' liability for taxes owed.
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