Deirdre G. McNamara - Page 6

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          Court asked petitioner to explain why she disagreed with                    
          respondent’s proposed collection action, petitioner failed to               
          provide any meaningful explanation.  We are satisfied that                  
          respondent did not abuse his discretion in making his                       
          determination.                                                              
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               To give effect to the foregoing,                                       
                                                   Decision will be entered           
                                             for respondent.                          





























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