MEMORANDUM FINDINGS OF FACT AND OPINION
WHERRY, Judge:
This proceeding arises from a petition filed in response to a Notice of Determination Concerning Collection Action under Section 6330 and a Notice of Determination Concerning Your Request for Relief pursuant to section 6015(f).
The issues for decision are:
(1) Whether petitioner was required to file a Federal income tax return for 1996;
(2) whether...
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