MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge:
The issue in this case is whether respondent has met the requirements of section 6320. All section references are to the Internal Revenue Code as amended.
FINDINGS OF FACT
When the petitions were filed, the Ledfords operated Service Engineering Trust, an entity located in Colorado Springs, Colorado, where they resided. The assessments relate to 1993, 1994, and 1995 Federal income taxes...
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