Rose Lynn Richmond - Page 14




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          492 (2002) (taxpayer barred under section 6330(c)(4) from raising           
          at hearing previously litigated statute of limitations issue).              
               In the absence of a spousal defense, a proper challenge to             
          the appropriateness of the intended collection action, or an                
          offer of a viable collection alternative, we shall sustain                  
          respondent’s determination to proceed with the proposed levy.               
               To reflect the foregoing,                                              
                                             Decision will be entered                 
                                        for respondent.                               






















               6(...continued)                                                        
          case supports respondent’s position that petitioner and her                 
          husband submitted their offer-in-compromise on Jan. 4, 1990, and,           
          therefore, the 1998 levy was timely.                                        





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