Ralph M. and Rosemary L. Conlon - Page 14

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          matters in issue.  Accordingly, for the reasons discussed above,            
          respondent’s determination to proceed by levy with the collection           
          of petitioners’ outstanding liability for 1991 should be                    
          sustained, and we so hold.                                                  
               We have considered all of petitioners’ arguments and                   
          contentions that are not discussed herein relating to whether               
          respondent may proceed with collection with respect to                      
          petitioners’ outstanding liability for 1991, and we find those              
          arguments and contentions to be without merit and/or irrelevant.            

               Reviewed and adopted as the report of the Small Tax Case               

               To give effect to the foregoing,                                       

                                                  Decision will be entered            
                                             for respondent.                          

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