MEMORANDUM OPINION
COLVIN, Judge:
On October 6, 2000, respondent sent petitioner a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 (the lien or levy determination), in which respondent determined that collection from petitioner of her unpaid tax, additions to tax, and interest for 1989-92 would proceed.
The sole issue for decision is whether respondent's refusal to consider petitioner's offer in compromise because...
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