MEMORANDUM FINDINGS OF FACT AND OPINION
SWIFT, Judge:
Petitioners seek review of respondent's notice of determination sustaining a notice of intent to levy relating to petitioners' 1993 Federal income tax liability.
All section references are to the Internal Revenue Code in effect for the year in issue.
Unless otherwise specified, references to petitioner in the singular are to petitioner Dennis Burbridge.
FINDINGS OF FACT
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