MEMORANDUM OPINION
GERBER, Judge:
Respondent, in a motion filed on October 27, 2003, moved for summary judgment on the question of whether he may proceed with the collection process with respect to petitioners. Respondent alleges that the section 6330 prerequisites have been met and that he should be allowed to proceed with collection of petitioners' assessed and outstanding tax liabilities. Petitioners' objection to respondent's motion was presented at...
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