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Based upon our review of the relevant evidence in this case,
we conclude that Luhmann did not abuse his discretion by
rejecting petitioners’ proposed collection alternative.
Consequently, we further conclude that Luhmann did not abuse his
discretion by sustaining the proposed levy to collect
petitioners’ unpaid income tax liabilities for 1999 and 2000.
We have considered the arguments of the parties that were
not specifically addressed in this opinion. Those arguments are
either without merit or irrelevant to our decision.
To reflect the foregoing,
Decision will be entered
for respondent.
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