CHIECHI, Judge:
The petition in this case was filed in response to a notice of determination concerning collection action(s) under section 6320 and/or 6330
FINDINGS OF FACT
Most of the facts have been stipulated and are so found.
At the time petitioners filed the petition in this case, they resided in New York, New York.
On December 12, 1996, petitioners jointly filed...
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