MEMORANDUM FINDINGS OF FACT AND OPINION
MARVEL, Judge:
Pursuant to section 6330(d), petitioner seeks review of respondent's determination to proceed with the collection of petitioner's 1997, 1998, and 1999 Federal income tax liabilities.
FINDINGS OF FACT
Some of the facts have been stipulated. We incorporate the stipulated facts and accompanying exhibits into our findings by this reference. Petitioner resided...
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