MEMORANDUM FINDINGS OF FACT AND OPINION
THORNTON, Judge:
Pursuant to sections 6320(c) and 6330(d), petitioner seeks review of respondent's determination sustaining the filing of a Federal tax lien with respect to petitioner's 1987 income tax.
FINDINGS OF FACT
The parties have stipulated most of the facts, which we incorporate herein by this reference. When petitioner filed his petition, he resided in Bergen...
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