HALPERN, Judge:
This case is before the Court to determine whether respondent may proceed with the collection of petitioner's unpaid Federal income tax for 1996 through 2006 and unpaid civil penalties for filing frivolous income tax returns for 1997, 1999, 2000, 2003, and 2004 (collectively, petitioner's liabilities or, simply, the liabilities). We review the determinations under section 6330(d)(1).
All section references are to the Internal Revenue...
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