Wayne Allen Mootz - Page 33




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               Based upon our examination of the entire record before us,             
          we find that respondent did not abuse respondent’s discretion in            
          making the determinations in the notice of determination with               
          respect to petitioner’s unpaid 2001 income tax liability and                
          petitioner’s unpaid 2002 income tax liability.  On that record,             
          we sustain those determinations.                                            
               We have considered all of the contentions and arguments of             
          petitioner that are not discussed herein, and we find them to be            
          without merit, irrelevant, and/or moot.                                     
               On the record before us, we shall grant respondent’s motion.           
               To reflect the foregoing,                                              


                                             An order granting respondent’s           
                                        motion and decision for respondent            
                                        will be entered.                              





















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