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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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Last modified: May 25, 2011