MEMORANDUM OPINION
SWIFT, Judge:
Petitioner seeks review of respondent's notice of determination sustaining respondent's notice of levy relating to petitioner's 1997, 1998, 1999, and 2001 Federal income tax liabilities.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect at all relevant times.
The issue for decision is whether respondent's Appeals Office abused its discretion in sustaining respondent...
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