MEMORANDUM OPINION
WELLS, Chief Judge:
The instant case is before us on respondent's motion for summary judgment pursuant to Rule 121. Pursuant to section 6330, respondent determined that the proposed collection action, relating to petitioner's 1991 and 1995 taxable years, was appropriate. Petitioner contends that respondent's motion for summary judgment should be denied because respondent did not consider a letter petitioner allegedly sent to respondent...
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