MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
On August 6, 2004, respondent sent petitioner a Decision Letter Concerning Equivalent Hearing Under Section 6320 in which respondent determined that a notice of Federal tax lien regarding petitioner's income taxes for 1995-96 would not be withdrawn. We sustain respondent's determination for reasons discussed below.
Unless otherwise stated, section references are to the Internal Revenue Code....
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