MEMORANDUM OPINION
VASQUEZ, Judge:
The controversy before us arises out of petitioners' opposition to respondent's motion to remand the case to the Appeals Office.
Background
On July 30, 2002, respondent issued a Notice of Federal Tax Lien filing to petitioners. The lien covered unpaid income tax for the taxable years 1989, 1993, 1995, 1996, and 1999. On September 9, 2002, petitioners filed a Form 12153, Request for a Collection...
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