MEMORANDUM OPINION
COHEN, Judge:
This case is before the Court on respondent's motion for summary judgment pursuant to Rule 121. The petition in this case was filed in response to a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 (notice of determination). The issue for decision is whether there was an abuse of discretion by the Internal Revenue Service (IRS) in determining that collection of petitioner's unpaid income...
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