William Reese - Page 13

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          making frivolous allegations such as that the IRS engaged in an             
          “egregious” pattern and practice of issuing excessive and                   
          wrongful assessments.                                                       
               For the foregoing reasons, we shall grant respondent’s                 
          motion for summary judgment.  We hold that respondent may proceed           
          with a levy with respect to petitioner’s 1988, 1989, 1990, 1991,            
          and 1992 tax years.                                                         

                                             An appropriate order and                 
                                        decision will be entered.                     





                                                                                     























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Last modified: May 25, 2011