Anthony Sciola - Page 8

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          that the Secretary failed to meet the requirements of any                   
          applicable law or administrative procedure.  Consequently, there            
          are no grounds upon which we could conclude that respondent’s               
          determination to proceed with collection was an abuse of                    
          discretion.  Lunsford v. Commissioner, 117 T.C. 183, 186 (2001);            
          Sego v. Commissioner, supra.                                                
               To reflect the foregoing,                                              
                                             Decision will be entered                 
                                        for respondent.                               































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