- 13 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13
Last modified: May 25, 2011