MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge.
The issue for decision is whether respondent abused his discretion in determining to proceed with collection.
FINDINGS OF FACT
On April 15, 1994, petitioners timely filed their 1993 Federal income tax return. On June 7, 1994, petitioners filed an amended return relating to that year. On January 9, 1996, respondent sent petitioners a notice of deficiency, determining a $20,710 deficiency...
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