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shall be credited against the tax liability for the collection of
which such levy was made. Sec. 6332(d)(1). Respondent’s
position is that if no payment is made to the IRS, petitioner
remains liable for his tax debt. We agree.
On the issue before us, we conclude that respondent did not
abuse his discretion with respect to the notice of determination.
Contentions we have not addressed are irrelevant, moot, or
without merit.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
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Last modified: May 25, 2011