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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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Last modified: May 25, 2011