MEMORANDUM OPINION
WELLS, Judge.
The instant matter is before the Court on respondent's and petitioners' motions for summary judgment pursuant to Rule 121. The issue we must decide is whether respondent's Appeals Office abused its discretion in determining to proceed with the collection of petitioners' 1989 tax liability. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references...
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