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determination that the notice of Federal tax lien filing was an
appropriate enforcement action with respect to petitioner’s 1995,
1996, 1997, 1998, and 1999 income tax liabilities.
To reflect the foregoing,
Decision will be entered
for respondent.
4(...continued)
two motions to quash subpoenas and denied petitioner’s motion for
a continuance, but petitioner did not file any motion for
reconsideration. We decline to reconsider our rulings on the
motions, which were explained in detail on the record before
trial.
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