MEMORANDUM FINDINGS OF FACT AND OPINION
SWIFT, Judge:
This case is before us on respondent's motion for partial dismissal due to lack of jurisdiction over respondent's proposed levy on petitioner's property for petitioner's unpaid Federal income taxes for 1984 through 1987, 1991 through 1993, and 1996, in the total amount of $122,202, and additional penalty and interest in the total amount of $59,182. Respondent concedes that we have jurisdiction over respondent...
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