MEMORANDUM OPINION
MORRISON, Judge.
The respondent (whom we refer to here as the IRS) notified petitioner Barry B. Kreisler that it intended to collect his 2000 income-tax liability by levy. Kreisler requested a pre-levy hearing with the IRS Appeals Office. After the hearing, he received an adverse determination from that office. He has appealed that determination to this Court. We sustain the determination.
Background
We adopt the stipulation...
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