MEMORANDUM OPINION
NIMS, 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), in which respondent determined to proceed with collection by levy of petitioner's Federal income tax liability for 1988 to 1992, inclusive, plus accrued interest and failure to pay penalty under section 6651(a)(3). Unless otherwise indicated, all section references...
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