§6123

t t the taxpayers and-they were given an opportunity to challenge the deficiencies in this .Court without first paying. the assessments . Also, section 6501(c)(4) does .not require that the written waiver be "filed with the Secretary"-as-required by section 6123(d) . Second, while-RA .Jackson attested that she remembered seeing signed forms, Mr. and Mrs . Marlow each provided-positive affirmations under oath that they did-not agree with the assessments and, most importantly, they. did not sign d