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Respondent provided petitioners with transcripts relating to
petitioners’ tax liabilities, took adequate steps to work with
petitioners toward a resolution of such liabilities, gave due
consideration to all of petitioners’ contentions relating to the
unpaid tax, and decided to proceed with the proposed collection
activity. Accordingly, respondent committed no error and may
proceed with the proposed collection activity.
Contentions we have not addressed are irrelevant, moot, or
meritless.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011