Peter and Margaret Giragosian - Page 8

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          Consequently, for the reasons discussed above, the Court will not           
          consider the matter.                                                        
               Petitioners received an appropriate hearing under section              
          6330(b)(1).  Day v. Commissioner, T.C. Memo. 2004-30; Leineweber            
          v. Commissioner, T.C. Memo. 2004-17; sec. 301.6330-1(d)(2), Q&A-            
          D6, Proced. & Admin. Regs.  Respondent properly verified that the           
          requirements of applicable law and administrative procedures were           
          met and balanced the need for efficient collection of taxes with            
          the legitimate concern of petitioners that the collection action            
          be no more intrusive than necessary.  On this record, the Court             
          holds that there was no abuse of discretion in sustaining the               
          notice of intent to levy.  Respondent, therefore, is sustained.             
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   


          An appropriate order and                                                    
          decision will be entered.                                                   

















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