MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge:
This case is based on a petition filed under section 6330(d) for review of a determination made by respondent's Office of Appeals (Appeals) that respondent's action to collect certain taxes may proceed. By Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330, dated February 24, 2000 (the notice), Appeals determined that respondent's Collection Division be allowed to...
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