MEMORANDUM OPINION
SWIFT, Judge:
Petitioner seeks our review under section 6330(d)(1)(A) of an adverse Appeals Office collection action determination. Respondent and petitioner cross move for summary judgment on all issues.
Unless otherwise indicated, all section references are to the Internal Revenue Code for the years in issue.
Background
The following facts are established by the record.
On April 20, 2000, respondent...
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