James Wilson Richmond, Jr. - Page 18

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          by the bankruptcy court did not include amounts paid before his             
          filing his petition with the bankruptcy court.                              
               Aside from challenging his underlying tax liability,                   
          petitioner did not raise any relevant issue relating to the                 
          proposed levy.  He offered no collection alternatives.  On the              
          basis of the foregoing we conclude that there was no abuse of               
          discretion by respondent’s Appeals officer.  All the requirements           
          of section 6330 have been satisfied, and respondent may proceed             
          with the proposed levy to collect the tax liability assessed                
          against petitioner for 2000.                                                
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             for respondent.                          























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Last modified: May 25, 2011