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In order to give effect to the foregoing,
An order granting respondent's
motion and decision for respondent,
including a penalty on petitioner
under section 6673(a)(1), will be
entered.
5(...continued)
secs. 6601(a), (e)(2), 6622. Further, petitioner’s allegation
regarding not receiving notice and demand is belied by the TXMODA
transcript of account, as well as the Nov. 10, 2000, final notice
(a copy of which was attached to petitioner’s Request for a
Collection Due Process Hearing), and the collection notice dated
Oct. 9, 2000 (see supra “C”). See, e.g., Hughes v. United
States, 953 F.2d 531, 536 (9th Cir. 1992); Weishan v.
Commissioner, T.C. Memo. 2002-88; see also Hansen v. United
States, 7 F.3d 137, 138 (9th Cir. 1993).
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Last modified: May 25, 2011