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instant case and that the exclusionary rule should not be
applied. We consider these contentions seriatim.
"Zone of Primary Interest"
In United States v. Janis, 428 U.S. 433, 458 (1976), the
U.S. Supreme Court mentioned a seizing officer's "zone of
primary interest" but did not elaborate on the phrase.
Courts have focused on officers' zones of primary interest
to predict whether applying the exclusionary rule in various
contexts would deter future unlawful searches and seizures.
See Grimes v. Commissioner, 82 F.3d 286, 290 (9th Cir.
1996); Wolf v. Commissioner, 13 F.3d 189, 194-196 (6th Cir.
1993), affg. T.C. Memo. 1992-432; Adamson v. Commissioner,
745 F.2d 541, 546 (9th Cir. 1984), affg. T.C. Memo. 1982-
371; Tirado v. Commissioner, 689 F.2d 307, 314 (2d Cir.
1982), affg. 74 T.C. 14 (1980); Black Forge, Inc. v.
Commissioner, 78 T.C. 1004, 1011-1012 (1982).
Presumably, if the proposed use of the evidence is close
to a seizing officer's zone of primary interest, the
inference is stronger that the officer had this use in mind
when making the seizure. Tirado v. Commissioner, supra at
311. To estimate an officer's zone of primary interest,
courts rely on commonsense assumptions about "human nature
and the interrelationship of the various components of the
law enforcement system." United States v. Janis, supra at
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