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entitlement to a release as a matter of law or right, and,
accordingly, petitioner has not shown an abuse of discretion. We
also note that petitioner and his representative were offered
proof that respondent had complied with the prerequisites of
sections 6320 and 6330 preliminary to proceeding with the filing
of a Notice of Federal Tax Lien or other collection activity.
Respondent’s Motion For Summary Judgment will be granted.
To reflect the foregoing,
An appropriate order and
decision will be entered for
respondent.
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Last modified: May 25, 2011