Craig I. Smith and Mary Lou Smith - Page 16

                                       - 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.                  

Page:  Previous  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16

Last modified: November 10, 2007