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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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Last modified: November 10, 2007