SUPPLEMENTAL MEMORANDUM OPINION
COLVIN, Judge:
Petitioner filed the petition in this case under section 6330(d) seeking our review of respondent's determination to collect amounts by jeopardy levy relating to petitioner's 1987-89 tax years. The sole issue remaining for decision is whether respondent's determination was an abuse of discretion. We hold that it was not.
Section references are to the Internal Revenue Code as amended.
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