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 the parties, the issues for decision are:
(1) Whether petitioner's arguments that (a) Synergistics/Blueprint Software (Synergistics), Lumenetics, and Data Flex partnerships were not properly subjected to the...
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