- 16 -
6330. Accordingly, this Court does not have jurisdiction to
review respondent’s decision to proceed by levy.10
To reflect the foregoing,
An appropriate order of
dismissal for lack of jurisdiction
will be entered.
10In view of our holding that we lack jurisdiction, we need
not address the issue of whether, as petitioners argued at trial
and on brief, respondent abused his discretion in proceeding with
collection by levy. However, for the sake of completeness, we
note that we do not find petitioners’ position persuasive.
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