MEMORANDUM OPINION
COHEN, Judge:
This proceeding was commenced in response to a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330. The issue for decision is whether there was an abuse of discretion in rejecting petitioner's offer to compromise for $100 petitioner's unpaid Federal income tax liabilities for 1997 and 1998 exceeding $13,600. Unless otherwise indicated, all section references are to the Internal Revenue Code...
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