MEMORANDUM FINDINGS OF FACT AND OPINION
HAINES, Judge.
Petitioners filed a petition with this Court in response to a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 (notice of determination) for 1995, 1996, 1997, 1998, 1999, 2000, 2001, and 2002 (years at issue).
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