MEMORANDUM OPINION
COLVIN, Judge:
This lien and levy case arising under section 6330(d) is before the Court on respondent's motion for summary judgment. The issue is whether it is appropriate to decide by summary judgment that respondent's determination to proceed with collection of petitioner's tax liabilities was not an abuse of discretion. For reasons stated below, we grant respondent's motion.
Except as otherwise noted, section references are...
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