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worthlessness. See sec. 166(a). Thus, petitioner presented no
evidence to support a deductible loss in any of the years in
issue. Had he done so, we would also have to consider whether
any of the loss-limitation provisions contained in the Code
apply. See, e.g., secs. 165(c), (g), 166(d), 267(a), 1211(b),
1212(b). Petitioner did not address any of these issues.
Petitioner argued in his request for continuance and at
trial that he needed more time to locate records to support his
alleged deductions. We shall not overturn and delay giving
effect to respondent’s determinations to proceed with collection
on the ground that petitioner should have another opportunity to
dispute the liabilities. The collection actions in the case at
hand relate to taxes due more than 5 to 10 years ago. We shall
not allow respondent’s collection actions to be held hostage to
petitioner’s allegations of possible deductions while he tries to
dragoon respondent into providing the evidence to support them.
Petitioner has failed to establish grounds for enjoining
respondent from proceeding by levy to collect the assessments at
issue. We therefore sustain respondent’s determinations to
proceed with collection.
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