MEMORANDUM FINDINGS OF FACT AND OPINION
JACOBS, Judge:
This case arises from petitioner's request for our review of respondent's determination that respondent's filing of a Federal tax lien with respect to the collection of petitioner's unpaid tax liability for 1997 was appropriate. The issue to be resolved is whether respondent abused his discretion in making that determination. In his trial memorandum, respondent raised the issue of whether petitioner...
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