- 5 -
anticipated under section 6330. To the contrary, petitioner and
petitioner’s representative were repeatedly notified of
respondent’s willingness to meet, of suggested dates and times
for a meeting, and of respondent’s willingness to consider any
specific, good faith issues raised by petitioner under section
6330(c)(2).
Petitioner makes only frivolous arguments.
Respondent’s Appeals Office did not abuse its discretion in
sustaining respondent’s lien filing. We shall grant respondent’s
motion for summary judgment.
An appropriate order and
decision will be entered.
Page: Previous 1 2 3 4 5
Last modified: May 25, 2011