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installment agreement. Based upon our examination of the entire
record before us, we find that respondent did not abuse respon-
dent’s discretion in determining to proceed with the collection
action as determined in the notice of determination with respect
to petitioner’s taxable year 2000.4
On the record before us, we shall grant respondent’s motion.
To reflect the foregoing,
An appropriate order granting
respondent’s motion and decision
will be entered for respondent.
4We have considered all of petitioner’s allegations and
contentions that are not discussed herein, and we find them to be
without merit and/or irrelevant.
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Last modified: May 25, 2011