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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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Last modified: November 10, 2007