MEMORANDUM OPINION
WELLS, Chief Judge:
Respondent issued to petitioner a Notice of Determination Concerning Collection Actions Under Section 6320 and/or 6330. In response to that notice, petitioner timely filed a Petition for Lien or Levy Action Under Code Section 6320(c) or 6330(d). We review for abuse of discretion respondent's Notice of Determination Concerning Collection Actions Under Section 6320 and/or 6330.
On May 23, 1997, respondent issued...
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