- 13 - In view of the foregoing, we hold that respondent's determinations to proceed with collection for the taxable years 1980, 1981, 1982, and 1983 are correct. Accordingly, we shall grant respondent's Motion for Partial Summary Judgment. To reflect the foregoing, An appropriate order will be issued granting respondent’s Motion for Partial Summary Judgment. 8(...continued) We also note that the District Court considered, and rejected, a statute of limitations defense that petitioner asserted in the civil collection action described supra.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13
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