Alfred A. Diffee, Jr. and Norma J. Diffee - Page 12




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               The uncontested record before us indicates that Officer                
          Clark’s adjustments were not arbitrary, capricious, or without              
          sound basis in law or fact.  See Woodral v. Commissioner, supra             
          at 23.  Officer Clark made reasonable adjustments by evaluating             
          petitioners’ disclosures on and attachments to their Form 433-A,            
          petitioners’ last filed Federal and State income tax returns, and           
          the Service’s national standards.  Accordingly, respondent did              
          not abuse his discretion in rejecting petitioners’ proposed                 
          installment agreement and sustaining the proposed collection                
          action.                                                                     
               We conclude that there is no genuine issue of material fact            
          requiring a trial in this case, and we hold that respondent is              
          entitled to the entry of a decision sustaining the proposed levy            
          as a matter of law.                                                         

                                                  An appropriate order and            
                                             decision will be entered.                



















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