Theodore A. Pride - Page 5

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               At trial, petitioner also questioned why a prior lien                  
          against his property filed in December 1990 was released against            
          his deceased spouse on August 30, 1999.  Although this issue had            
          not been raised at the hearing before the Appeals officer,                  
          respondent subsequently provided petitioner with transcripts of             
          the liability of his deceased spouse, reflecting assessments of             
          the same amounts of liabilities for 1978 through 1982 as had been           
          determined against petitioner and unpaid balances for 1980                  
          through 1982 in the same amounts as those involved in this                  
          proceeding.  There is no indication that the lien was released as           
          a result of payments made by petitioner’s spouse.                           
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             for respondent.                          

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