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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.
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