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HALPERN, J., concurring: I concur with the result reached
by the majority. In my concurring report in Lunsford v.
Commissioner, 117 T.C. ___ (2001), I have offered some comments
concerning our authority to dictate to respondent the nature of
the hearing required by section 6330(b). I incorporate those
comments herein by this reference.
WHALEN, BEGHE, and THORNTON, JJ., agree with this concurring
opinion.
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