Johnnie L. Tillman - Page 8

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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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