Edward Kazuo Ozaki - Page 4

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          liabilities for those years, see sec. 6330(c)(2)(B), we review              
          Appeals' determination for an abuse of discretion, see Sego v.              
          Commissioner, supra at 610.  Petitioner claims no specific abuse            
          of discretion on the part of Appeals in making its determination,           
          nor do we find any such abuse.  As we understand petitioner’s               
          sole position in this case, he claims that he has a mental                  
          condition (similar to paranoia) resulting from racial injustice             
          against his ancestors and that this condition and injustice                 
          entitle him to relief from the lien.  Those allegations, however,           
          do not establish that Appeals abused its discretion as to any               
          part of the determination at issue.  We sustain Appeals’                    
          determination in its entirety.  We have considered all arguments            
          made by petitioner for a contrary holding and found those                   
          arguments not discussed herein to be without merit.  To reflect             
          the foregoing,                                                              

                                                  Decision will be entered            
                                             for respondent.                          
















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