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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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Last modified: May 25, 2011