W. Richard and Janice J. Morgan - Page 11




                                       - 11 -                                         
          so petitioners suffered no prejudice.  The same rationale applies           
          here.                                                                       
               We conclude that respondent’s determination was not an abuse           
          of discretion.  We sustain respondent’s administrative                      
          determination to proceed with collection of the 1983 tax                    
          liability.                                                                  
                                                  Decision will be entered            
                                             for respondent.                          


































Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  

Last modified: May 25, 2011