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Discussion
The driving force of petitioner’s prayers for relief seems
to be the adverse effect of the tax lien on her ability to obtain
employment in the Nevada gaming industry. It is common practice
in the Nevada gaming industry to run credit checks on prospective
employees who will be handling large amounts of cash and to hire
only those whose credit is unblemished. ETT Gaming, among others
who checked petitioner’s credit, apparently regarded the Federal
tax lien disclosed by the report as a blemish. Petitioner, who
has worked in the Nevada gaming industry since 1976, blames the
adverse credit report for her inability to find work, and we have
no reason to believe otherwise. Although petitioner’s prayers
for relief are wrapped in a request for administrative and
litigation costs, petitioner’s motion papers suggest she is
actually complaining about consequential damages for which the
tax law provides no relief.
Whatever the source of petitioner’s request, she cannot
prevail in this proceeding. Before analyzing petitioner’s
request for costs under section 7430 and setting forth the
technical grounds for denying her motion, we explain petitioner’s
role in causing her predicament.
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Last modified: May 25, 2011