Peter J. Tkac - Page 5




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          tax liability.  In that regard, because of respondent’s                     
          concession, petitioner’s motion to dismiss is moot.  Accordingly,           
          the Court holds that respondent may not collect petitioner’s                
          unpaid and outstanding income tax liability for 1992 with respect           
          to the notice of intent to levy issued by respondent as to that             
          year.  That holding provides petitioner with relief beyond what             
          he asked for in his petition and motion as to the 1992 income tax           
          liability over which we have jurisdiction.                                  
               To reflect the foregoing,                                              
                                             An appropriate order and                 
                                        decision will be entered.                     





























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