- 33 - 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.Page: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33Last modified: November 10, 2007