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arrangements before them are of the sort that would warrant
excluding the evidence. Grimes v. Commissioner, supra at
290 (no preexisting implicit or explicit agreement); Wolf v.
Commissioner, supra at 195 (no explicit agreement); Tirado
v. Commissioner, supra at 314-315 (no general policy,
liaison agreement, or specific agreement on specific case
regarding exchange of information; no explicit and
demonstrable understanding); Guzzetta v. Commissioner, supra
at 180-182 (discretionary liaison insufficient); Black
Forge, Inc. v. Commissioner, supra at 1011 (no prior
agreement).
We reject petitioner's contention that the Blaine,
Washington, DEA office practice of periodically permitting
IRS agents to review case files mandates application of the
exclusionary rule. Petitioner's position that a seizing
officer's agency need not be involved in an agreement to
mandate application of the exclusionary rule is unsupported
and unpersuasive. See United States v. Janis, supra at 448
(seizing officer is primary object of sanction). Petitioner
argues that suppressing the evidence will achieve deterrence
because, although the alleged agreement was between the IRS
and DEA, the Border Patrol officer who seized the evidence
was authorized by the DEA to enforce certain Federal
narcotics violations. We cannot conclude that deterrence
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