Pearlena Wallace - Page 8




                                        - 7 -                                         
          Commissioner, T.C. Memo. 2003-117; Tabak v. Commissioner, T.C.              
          Memo. 2003-4.                                                               
               We are satisfied that in all other respects respondent has             
          complied with the procedures contemplated by section 6330, and              
          petitioner has in no way suggested otherwise.  It follows that              
          respondent may proceed with collection as proposed in the above-            
          referenced notice of determination.                                         
               To reflect the foregoing,                                              

                                             Decision will be entered                 
          for respondent.                                                             





























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