MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
Respondent sent petitioner a Notice of Determination Concerning Collection Action Under Section 6320 (the lien determination) in which respondent determined that the notice of Federal tax lien regarding petitioner's income tax liabilities for 1994-99 was appropriate and would not be withdrawn.
The issues for decision are:
1. Whether petitioner may dispute the existence or amount of his...
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