MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge:
Petitioner appealed to this Court from respondent's determination to go forward with the collection of petitioner's outstanding and unpaid 1995 and 1996 tax liabilities. This case was calendared for trial at the Court's March 24, 2003, Los Angeles, California, trial session. On March 31, 2003, the parties appeared, and petitioner provided testimony and argument. Respondent contends and we agree that...
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