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pay and was not a valid collection alternative to the proposed
levy. This conclusion was not arbitrary and capricious. There
is no genuine issue as to any material fact, and respondent is
entitled to judgment as a matter of law. Accordingly,
respondent’s motion for summary judgment will be granted.
Reviewed and adopted as the report of the Small Tax Case
Division. To reflect the foregoing,
An order granting respondent's
motion for summary judgment and decision
for respondent will be entered.
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Last modified: May 25, 2011