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verified that respondent had complied with all legal and
procedural requirements pertaining to the proposed levy. In
addition, the Appeals officer balanced the need to efficiently
collect tax with concerns that the means of collection be no more
intrusive than necessary. Finally, because of a lack of viable
collection alternatives, the Appeals officer concluded that the
proposed levy was legally and procedurally correct.
Accordingly, we hold that respondent’s determination to
proceed with collection of petitioner’s 1994 tax liability was
not an abuse of discretion.
To reflect the foregoing,
An order will be issued
granting in part and denying in
part respondent’s motion for
summary judgment and denying
petitioner’s cross-motion.
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Last modified: May 25, 2011