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respondent abused his discretion in sustaining the Federal tax
lien. Petitioner has yet to pay his outstanding tax liability
for 1998. While an installment agreement has been entered into
for petitioner’s outstanding tax liability, that agreement does
not preclude respondent from maintaining a lien while taxes are
still outstanding. Secs. 6322 and 6323(j); cf. sec. 301.6323(j)-
1, Proced. & Admin. Regs. (Commissioner may withdraw a notice of
Federal tax lien under certain conditions). On the basis of the
facts presented, we hold that respondent did not abuse his
discretion in upholding the Federal tax lien.
We have considered all of petitioner’s contentions,
arguments, and requests, and to the extent that they are not
discussed herein, we conclude them to be moot, irrelevant, or
without merit.
To reflect the foregoing,
An appropriate order of
dismissal and decision will be
entered.
[Reporter’s Note: This report was amended by order dated August 3, 2005.]
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