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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.
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