MEMORANDUM FINDINGS OF FACT AND OPINION
WELLS, Judge:
Pursuant to section 6330(d), petitioners seek judicial review of respondent's determination to proceed with a proposed levy concerning petitioners' 1994 Federal income tax liability. The issue to be decided is whether respondent's determination was an abuse of discretion. All section references are to the Internal Revenue Code, as amended.
FINDINGS OF FACT
Some of the facts have been...
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