MEMORANDUM OPINION
HALPERN, Judge.
This case is before the Court to review a determination (the determination) by respondent's Appeals Office (Appeals) to proceed with the collection of petitioner's Federal income tax liabilities for 2000, 2001, and 2002. We review the determination pursuant to sections 6320(c) and 6330(d)(1).
All section references are to the Internal Revenue Code of 1986, as amended and as applicable...
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