MEMORANDUM FINDINGS OF FACT AND OPINION
JACOBS, Judge.
This case arises from petitioner's request for our review of respondent's determination that the filing of a Federal tax lien with respect to the collection of petitioner's unpaid taxes for 1996 and 1997 was appropriate. The issue to be resolved is whether that determination by respondent constitutes an abuse of discretion. Respondent raised the issue of whether petitioner should be required to pay a...
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