Mark Fowler and Joylyn Souter-Fowler - Page 16

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          $2,400.  We further hold that respondent did not abuse his                  
          discretion in sustaining the filing of the Notices of Federal Tax           
          Liens.7                                                                     
                                             An appropriate decision will             
                                        be entered.                                   





























               7 Petitioners have made no argument of merit from which an             
          abuse of discretion could be found with respect to respondent’s             
          determination that the filing of the Notices of Federal Tax Liens           
          was appropriate.                                                            





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