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regard to whether respondent’s determination to proceed with
collection for 1995, 1996, 1998, and 1999 was an abuse of
discretion. We therefore shall deny respondent’s motion with
respect to 1997 and grant summary judgment with respect to 1995,
1996, 1998, and 1999.
To reflect the foregoing,
An appropriate order
will be issued granting
in part and denying in
part respondent’s motion
for summary judgment.
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