MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge.
The issue for decision is whether respondent abused his discretion in determining to proceed with collection.
FINDINGS OF FACT
Petitioner failed to file income tax returns relating to 1994, 1995, and 1996. (Exhibit 1, Declaration of James H. Reagan) On December 28, 1998, respondent assessed deficiencies against petitioner relating to those years. (Exs. AD, p.3) As of July 31, 2001, petitioner...
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