Mark Lewis Tracton - Page 10




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          entitled to a decision in his favor.  We therefore conclude that            
          respondent did not abuse his discretion in sustaining the notice            
          of Federal tax lien.                                                        
               We have considered all the remaining arguments made by the             
          parties for results contrary to those expressed herein, and to              
          the extent not discussed, we conclude those arguments are moot,             
          without merit, or unnecessary to reach.                                     
               To reflect the foregoing,                                              
                                             Decision will be entered                 
                                        for respondent.                               






























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Last modified: November 10, 2007