MEMORANDUM OPINION
HALPERN, Judge:
This case is before the Court to review a determination (the determination) by respondent's Appeals Office (Appeals) to proceed with the collection by levy of petitioner's Federal income tax liability for 1999. We review the determination pursuant to section 6330(d)(1).
Unless otherwise indicated, all section references are to the Internal Revenue Code of 1986, as amended and as applicable...
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