MEMORANDUM OPINION
SWIFT, Judge:
This matter is before us on respondent's Rule 121 motion for summary judgment and petitioner's opposition thereto.
The issue for decision is whether respondent's Appeals Office abused its discretion in sustaining a notice of levy against petitioner without offering petitioner a face-to-face hearing.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in...
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