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find no such conduct in the instant case. Although it is
not standard practice in the Border Patrol to ask people who
are carrying large amounts of currency questions about tax
returns, Reese explained that he asked petitioner tax
questions to determine whether petitioner had a legitimate
source for his income. Reese's questions about petitioner's
tax returns in the circumstances of this case do not
indicate that tax violations were in his zone of primary
interest.
Agreement Between Agencies
Petitioner contends that an agreement to share
information between agencies in this case mandates
application of the exclusionary rule. Courts frequently
examine whether agreements exist between agencies, to
determine whether suppressing evidence illegally obtained by
one agency and offered by another will deter future unlawful
searches and seizures. Grimes v. Commissioner, supra at
290; Wolf v. Commissioner, supra at 195; Tirado v.
Commissioner, supra at 314-315; Guzzetta v. Commissioner, 78
T.C. 173, 180-182 (1982); Black Forge, Inc. v. Commissioner,
supra at 1011. Although generally recognizing that such
agreements increase the likelihood that deterrence will be
achieved by applying the exclusionary rule, courts have
considered a variety of elements in determining whether the
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