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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