MEMORANDUM FINDINGS OF FACT AND OPINION
GOEKE, Judge:
This case arises from respondent's issuance of a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 for petitioner's taxable year 1998. The sole issue for decision is whether respondent's determination to proceed with collection of petitioner's 1998 assessed tax liability was an abuse of discretion. Because petitioner has not raised any relevant issues relating to the...
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