MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge:
Respondent, on March 14, 2002, issued a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 (notice of determination), with regard to petitioner's 1991 and 1996 taxable years, determining to proceed with enforced collection, including levy. Petitioner timely petitioned this Court seeking to dispute the underlying merits of his tax liabilities for 1991 and 1996 and to...
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