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May 11, 12, or 13. Thus, the date the lien notice was prepared
and signed has no significance and does not bear on whether there
was an abuse of discretion in this case.
Based upon the record before us, we have determined that
there is no genuine issue of material fact. We hold that the
settlement officer’s determination sustaining the Notice of
Federal Tax Lien filing was not an abuse of discretion. We
therefore shall grant respondent’s motion for summary judgment.
We have considered all of the parties’ contentions and
arguments that are not discussed herein, and we find them to be
without merit, irrelevant, and/or moot.
An appropriate order and
decision will be entered for
respondent.
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Last modified: November 10, 2007