MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge:
The petition in this case was filed in response to a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 (notice of determination). After concessions by petitioner, the issue for decision is whether there was an abuse of discretion by the Internal Revenue Service (IRS) in determining that collection of petitioner's unpaid income tax liabilities for 1986 through 1996...
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