MEMORANDUM OPINION
VASQUEZ, Judge:
This case is before the Court on respondent's motion to dismiss on the ground of mootness (the motion). The issue for decision is whether petitioner's case is moot.
Background
On or about April 12, 2001, respondent issued a "Final Notice of Intent to Levy and Notice of Your Right to a Hearing" to petitioner for his tax liabilities for 1989, 1993, 1994, and 1996. On...
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