OPINION Halpern, Judge: This case is before the Court to review determinations made by respondent’s Appeals Office (Appeals) that respondent may proceed to collect by levy amounts assessed but' unpaid with respect to petitioner Juanita Kendricks’s 1982 through 1984 taxable (calendar) years and petitioners Juanita and Emmanuel Kendricks’ 1985 taxable (calendar) year (col…
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