- 9 - 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.Page: Previous 1 2 3 4 5 6 7 8 9Last modified: November 10, 2007