MEMORANDUM FINDINGS OF FACT AND OPINION
GOEKE, Judge:
This case arises from respondent's issuance of a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 for petitioner's taxable year 1997. Respondent has filed both a notice of Federal tax lien filing and a notice of intent to levy against petitioner for his 1997 unpaid tax liability. The issues for decision are: (1) Whether petitioner is entitled to a new Appeals Office...
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