THORNTON, Judge:
Petitioner seeks review under section 6330(d) of a determination made by respondent's Office of Appeals that respondent's action to collect by levy certain income taxes for 1989, 1990, 1991, 1992, 1993, 1996, and 1997 may proceed. Petitioner contests the levy on grounds that respondent is time barred from collecting taxes for taxable years 1989 and 1990, and that petitioner has already paid the subject tax liabilities for the other years in...
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