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C. Conclusion
Petitioner has not shown that respondent’s determination was
arbitrary or capricious, or without sound basis in fact or law.
For all of the above reasons, we hold that respondent’s
determination was not an abuse of discretion, and respondent may
proceed with the proposed collection action.
In reaching our holdings herein, we have considered all
arguments made, and, to the extent not mentioned above, we find
them to be moot, irrelevant, or without merit.
To reflect the foregoing,
Decision will be
entered for respondent.
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