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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
Division.
To give effect to the foregoing,
Decision will be entered
for respondent.
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