MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
On August 11, 2000, respondent sent petitioner a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 (the lien or levy determination), in which respondent determined to proceed with collection of deficiencies in petitioner's income tax, additions to tax, and interest for 1988-89. Petitioner did not file tax returns for tax years 1988-2000.
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