Dina DeSalvo - Page 15

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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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