MEMORANDUM OPINION
MARVEL, Judge.
This matter is before the Court on respondent's motion for summary judgment and to impose a penalty under section 6673(a)(1).
Background
This is an appeal from respondent's determination upholding the proposed use of a levy to collect petitioner's unpaid Federal income tax liabilities for 1991 through 1998 and 2002. Petitioner resided in Endicott,
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