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outcome or holding resulting from that opportunity may be in
error. Id.
In addition, respondent has, in all other respects, complied
with the requirements of section 6330 so as to be entitled to
proceed with collection of petitioner’s outstanding tax
liabilities for 1991 and 1996. We hold that there was no abuse
of discretion in respondent’s determination to proceed with
collection.
To reflect the foregoing,
Decision will be entered for
respondent.
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Last modified: May 25, 2011