Deavrah M. Chandler - Page 10

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          a hearing before anyone other than the Office of Appeals.  Sec.             
          6330(b).                                                                    
               We conclude, therefore, that the matters disputed by                   
          petitioner are not material, that the material facts are not in             
          dispute, and that respondent is entitled to judgment as a matter            
          of law.                                                                     
                                                  An appropriate order and            
                                             decision will be entered.                
































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