MEMORANDUM OPINION
HALPERN, Judge:
Pursuant to section 6330(d), petitioner seeks review of respondent's determination to proceed with collection of income taxes and additions to tax for calendar years 1982, 1987, and 1988 (sometimes, the years in issue).
Unless otherwise indicated, all section references are to the Internal Revenue Code as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure. All dollar amounts have...
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