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sustained. The levy action is necessary in the inter-
est of effective tax administration because the tax-
payer has not fully cooperated with the Service Center
or Appeals and has not filed tax returns for the years
1997 thru 2001. [Reproduced literally.]
Discussion
The Court may grant summary judgment where there is no
genuine issue of material fact and a decision may be rendered as
a matter of law. Rule 121(b); Sundstrand Corp. v. Commissioner,
98 T.C. 518, 520 (1992), affd. 17 F.3d 965 (7th Cir. 1994). We
conclude that there are no genuine issues of material fact
regarding the questions raised in respondent’s motion.
Where, as is the case here, the validity of the underlying
tax liability is not properly placed at issue, the Court will
review the determination of the Commissioner of Internal Revenue
for abuse of discretion. Sego v. Commissioner, 114 T.C. 604, 610
(2000); Goza v. Commissioner, 114 T.C. 176, 181-182 (2000).
In her petition, petitioner alleges:
I should not owe any taxes nor penalties & inter-
est for neither of these three tax years. I do not
know why I owe for 1988. I participated in an audit
face-to-face for 1989 and gave all documents requested
to prove any claimed deductions. The IRS audit person
concluded after about 1� year [sic] and had not fin-
ished (to my memory). * * * The paperwork I saw disal-
lowed many legitimate deductions and I don’t understand
that.
Based upon our examination of the entire record before us,
we find that respondent did not abuse respondent’s discretion in
determining to proceed with the collection actions as determined
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