- 14 - received the notice of determination with an attached transcript of his 1997 tax liability. Accordingly, we hold there was no abuse of discretion in respondent’s determination to proceed with collection of petitioner’s 1997 tax liability. We have considered all of petitioner’s arguments, and to the extent that they are not mentioned herein, we find them to be moot, irrelevant, or without merit. To reflect the foregoing, Decision will be entered permitting respondent to proceed with collection.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14
Last modified: May 25, 2011