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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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Last modified: May 25, 2011