MEMORANDUM OPINION
COHEN, Judge.
This case was commenced in response to a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330. The notice of determination sustained a proposed levy with respect to petitioner's unpaid taxes for 1986, 1990, 1991, 1992, 1993, 1994, 1995, 1997, and 1999. The issue for decision is whether the Appeals officer's rejection of petitioner's Form 656, Offer in Compromise, was an abuse of discretion...
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