- 10 -
2006-88; Ho v. Commissioner, T.C. Memo. 2006-41; Leineweber v.
Commissioner, T.C. Memo. 2004-17. Petitioner was given the
opportunity for a hearing and failed to take advantage of it. We
conclude, therefore, that there is no genuine issue of material
fact requiring a trial, that the undisputed facts in the record
establish that respondent did not abuse his discretion in
determining that the proposed collection action could proceed,
and that respondent is entitled to a summary disposition
upholding his proposed collection action with respect to
petitioner’s unpaid tax liabilities for 1990 through 1993.
We shall grant respondent’s motion for partial summary
judgment.
An appropriate order
will be issued.
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Last modified: March 27, 2008