MEMORANDUM FINDINGS OF FACT AND OPINION
GOEKE, Judge.
These consolidated cases concern: (1) A notice of determination concerning collection action (notice of determination) upholding liens under section 6320 for petitioners' taxable years 1997 through 1999; (2) a notice of determination upholding a levy under section 6330 for petitioners' taxable year 1999; (3) a notice of determination upholding a lien for petitioners' taxable year 2000.
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