MEMORANDUM OPINION
LARO, Judge:
Petitioners, while residing in Murrieta, California, petitioned the Court under section 6330(d) to review respondent's proposed collection activity in the form of a levy. Respondent proposed this action to collect petitioners' joint Federal income tax liability for 1994 and 1995. Currently, the case is before the Court on respondent's motion for summary judgment under Rule 121(a). Petitioners responded to respondent's motion...
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