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We infer that the failure to eliminate petitioner’s total
liability for the 3 years in issue by a single payment of $100, a
result that petitioner’s representative had achieved in other
cases, led to the pursuit of this proceeding in response to what
otherwise would be regarded as a favorable determination.
Petitioner has not offered, nor have we found in the record, any
reason why the determination to suspend collection and not to
pursue levies is an abuse of discretion. That his representative
achieved a $100 compromise of liabilities in other cases is
irrelevant. We conclude that the material facts are not in
dispute and that respondent is entitled to judgment as a matter
of law.
To reflect the foregoing,
An appropriate order and
decision will be entered.
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Last modified: May 25, 2011