- 14 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Last modified: May 25, 2011