MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge.
The issue for decision is whether respondent may proceed with his proposed collection activity relating to petitioner's 1994 tax liability.
FINDINGS OF FACT
Petitioner failed to file his 1994 Federal income tax return. On April 18, 1997, respondent sent petitioner a notice of deficiency. On May 23, 1997, respondent sent petitioner a second notice, which corrected a typographical error...
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