MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge:
On December 14, 2000, respondent issued a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 advising petitioner of respondent's intention to proceed with a proposed levy to collect petitioner's outstanding income tax liabilities for 1991, 1992, 1993, and 1994. A petition was filed on January 12, 2001, in which petitioner...
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