OPINION
WHERRY, Judge:
This matter is before the Court on respondent's motion for summary judgment. In a May 7, 2008, Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330, respondent determined that it was appropriate to collect petitioner's unpaid income tax liabilities and additions to tax (unpaid tax liabilities) for 1997, 1998, 1999, and 2002 by serving a notice of jeopardy levy. Petitioner on June 6, 2008, timely...
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