MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge:
The issue for decision is whether respondent abused his discretion in determining to proceed with collection of petitioners' 1997 tax liability.
FINDINGS OF FACT
On April 1, 1999, John and Donna Ringgold (petitioners) executed and sent respondent Form 4549-CG, Income Tax Examination Changes, in which petitioners agreed to the immediate assessment and collection of additional tax liabilities...
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