- 11 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11Last modified: March 27, 2008