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6320 or 6330. See Speltz v. Commissioner, supra at 180.
Accordingly, we need not and do not decide whether petitioners
would suffer an economic hardship if respondent pursued a levy
action.
On the basis of our review of the record, we conclude that
respondent satisfied the requirements of section 6330(c) and did
not abuse his discretion by rejecting petitioners’ OIC and
sustaining the notice of Federal tax lien filed against
petitioners. Respondent’s determination therefore is sustained.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011