Harley Gunderson - Page 7




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          spousal defenses, any challenges to the appropriateness of the              
          collection actions, or any offers of collection alternatives.               
          See sec. 6330(c)(2)(A).  There is no basis in the record for the            
          Court to conclude that respondent abused his discretion with                
          respect to any of these matters.                                            
               In reaching all of our holdings herein, we have considered             
          all arguments made by the parties, and, to the extent not herein            
          discussed, we find them to be irrelevant or without merit.                  
               To reflect the foregoing,                                              
                                             An appropriate order and                 
                                        decision will be entered granting             
                                        respondent’s motion for summary               
                                        judgment.                                     

























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