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Petitioners have failed to present grounds on which this
Court could find that the Appeals officer abused her discretion
in sustaining the proposed levy. Accordingly, collection by levy
of petitioners’ unpaid 1996 tax liability reflected in the notice
of determination may proceed.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be
entered for respondent.
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Last modified: May 25, 2011