Stephen Mitchell Day - Page 9

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          did not abuse his discretion with respect to any of the matters             
          in issue.                                                                   
               For the reasons discussed above, respondent’s determination            
          to proceed by levy with the collection of petitioner’s                      
          outstanding liabilities for 1995 and 1996 should be sustained,              
          and we so hold.  We have considered all of petitioner’s arguments           
          and contentions that are not discussed herein relating to whether           
          respondent may proceed with collection with respect to                      
          petitioner’s outstanding liabilities for 1995 and 1996, and we              
          find those arguments and contentions to be without merit and/or             
          irrelevant.                                                                 
               To reflect the foregoing,                                              
                                                   Decision will be entered           
                                             for respondent.                          























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