Craig H. Bond and Jennifer Bond - Page 9




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          from contesting their 2001 tax liability.  Because petitioners’             
          underlying tax liability is not properly at issue, we review the            
          determination made by the Appeals Office for abuse of discretion.           
          As petitioners raise no other arguments pertaining to the                   
          appropriateness of the proposed collection action, we hold that             
          Mr. Heidle did not abuse his discretion in upholding the validity           
          of the notice of Federal tax lien filing.                                   
               On this record, we conclude that there is no genuine issue             
          of material fact requiring a trial, and we hold that respondent             
          is entitled to the entry of a decision sustaining the lien as a             
          matter of law.                                                              
               To reflect the foregoing,                                              

                                                  An appropriate order and            
                                             decision will be entered.                






















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