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present any evidence at trial that the Appeals officer failed to
consider collection alternatives or failed to apply the
appropriate law to petitioner’s circumstances.
The record is devoid of any evidence establishing that
respondent abused his discretion in determining to proceed with
collection of petitioner’s tax liabilities. On the record before
us, the Court finds that respondent did not abuse respondent’s
discretion in making that determination.
The Court has considered all of petitioner’s arguments and
contentions that are not discussed herein relating to whether
respondent may proceed with collection with respect to
petitioner’s taxable years 1997 and 2000, and the Court concludes
they are without merit or irrelevant.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011