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| | Fact Finding |
 | | Held: R's Appeals officer did not abuse his discretion by sustaining a determination to proceed with collection by levy of P's unpaid liabilities following a telephonic conversation and an exchange of correspondence with P. P failed to prove that she requested a face-to-face interview with the Appeals officer during the course of the sec. |
 | | MEMORANDUM FINDINGS OF HALPERN, Judge: This case is before the Court to review a determination (the determination) made by respondent's Appeals Office (Appeals) that respondent may proceed to collect by levy petitioner's tax liabilities for her 1988, 1993, 1994, 1996, 1997, and 1998 taxable (calendar) years. |
 | | FINDINGS OF The parties filed a stipulation of facts, which, with accompanying exhibits, is incorporated herein by reference. |
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