MEMORANDUM FINDINGS OF FACT AND 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 1993 through 1996. During the trial, the parties made concessions with respect to 1993-95. Respondent conceded that collection is improper for 1993. Petitioner conceded, and respondent agreed, that collection for 1994 is proper after application...
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