MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
Respondent sent petitioner a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 (the lien or levy determination) on May 18, 2001, in which respondent determined to proceed with collection of deficiencies in petitioner's income tax, additions to tax, and interest for 1996.
The sole issue for decision is whether...
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