John Shere - Page 11




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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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