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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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Last modified: May 25, 2011