RIVERA v. COMMISSIONER

MEMORANDUM FINDINGS OF FACT AND OPINION

FOLEY, Judge:

The issues for decision are whether respondent correctly determined the amounts of petitioner's tax liabilities and whether respondent abused his discretion in proceeding with collection.

FINDINGS OF FACT

Respondent assessed petitioner's Federal income tax liability relating to 1977 through 1992, 1994, and 1997 as follows:

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