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is no genuine issue of material fact within the record that would
show the settlement officer abused his discretionary power.
Due to the above reasoning, this Court finds that there is
no genuine issue of material fact in the present case, and we
hold for the respondent as a matter of law. Respondent’s Motion
for Summary Judgment is granted.
Reviewed and adopted as the report of the Small Tax Case
Division.
An appropriate order and
decision will be entered granting
respondent’s Motion for Summary
Judgment.
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Last modified: May 25, 2011