Ella Louise Wooten - Page 13

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          conclude as a matter of law that respondent did not abuse his               
          discretion in determining to sustain the notice of lien and to              
          proceed with collection of the tax liabilities and interest                 
          assessed against petitioner.                                                
               There are no genuine issues of material fact.  Summary                 
          judgment is appropriate, see Rule 121(b), and we shall therefore            
          grant respondent's motion for summary judgment.                             
                                             An appropriate order and                 
                                        decision will be entered.                     































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