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establish that petitioner was given an opportunity for a hearing,
and he failed to take advantage of it. Respondent reasonably
concluded that the collection action could proceed after
reviewing the administrative record and determining that the
requirements of section 6330 had been satisfied.
We conclude on the record before us that respondent did not
abuse his discretion in determining that the proposed levy could
proceed. See Peter D. Dahlin Atty. at Law, P.S. v. Commissioner,
T.C. Memo. 2007-310; Davis v. Commissioner, T.C. Memo. 2007-160.
There is no genuine issue of material fact requiring a trial in
this case, and we hold that respondent is entitled to the entry
of a decision sustaining the proposed levy as a matter of law.
An appropriate order and
decision will be entered.
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Last modified: March 27, 2008