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D. Conclusion
For the reasons discussed above, respondent’s determination
to proceed by levy with the collection of petitioners’
outstanding liabilities for 1992 and 1993 should be sustained,
and we so hold.
Reviewed and adopted as the report of the Small Tax Case
Division.
To give effect to the foregoing,
Respondent’s Motion For
Summary Judgment will be denied as
moot, and decision will be entered
for respondent.
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