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Discussion
The Court may grant summary judgment where there is no
genuine issue of material fact and a decision may be rendered as
a matter of law. Rule 121(b); Sundstrand Corp. v. Commissioner,
98 T.C. 518, 520 (1992), affd. 17 F.3d 965 (7th Cir. 1994). We
conclude that there is no genuine issue of material fact regard-
ing the questions raised in respondent’s motion.
Petitioner did not dispute the existence or the amount of
petitioner’s unpaid liability for 2000 at the Appeals Office
hearing or in the petition that she filed in this case. We shall
review the notice of determination for abuse of discretion. See
Sego v. Commissioner, 114 T.C. 604, 610 (2000); Goza v. Commis-
sioner, 114 T.C. 176, 181-182 (2000).
The settlement officer considered all of the allegations and
contentions in petitioner’s Form 12153 and in her submissions to
such settlement officer. During the Appeals Office hearing that
the settlement officer held with petitioner, the settlement
officer discussed possible collection alternatives with her,
including posting a bond, substituting collateral, or paying in
full petitioner’s unpaid liability for 2000. In addition, the
settlement officer considered whether there were grounds under
section 6323(j) to withdraw the notice of lien. At no time in
connection with the Appeals Office hearing did petitioner submit
an offer-in-compromise to the settlement officer or request an
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