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For his part, petitioner has offered no credible evidence
showing that respondent’s determination was arbitrary,
capricious, or without sound basis in law. We therefore conclude
that these is no genuine issue of material fact and that
respondent is entitled to an entry of decision as a matter of
law.
Based upon our review of the relevant evidence and law in
this case, we sustain the determination of respondent to proceed
with the proposed collection action to collect petitioner’s
unpaid income tax liabilities for taxable years 1999 and 2000.
To reflect the foregoing,
An appropriate order and
decision will be entered for
respondent.
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Last modified: November 10, 2007