MEMORANDUM FINDINGS OF FACT AND OPINION
DEAN, Special Trial 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). Pursuant to section 6330(d), petitioner seeks review of respondent's proposed levy with respect to her income tax liabilities for 1994, 1995, 1996, and 1997. The issue for decision is whether respondent's determination to proceed...
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