Tsutomu Tedokon - Page 14




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          of his own making because of his leisurely attitude toward the              
          due date for filing his 1991 return, and the refund claim within            
          it.                                                                         
               We hold that respondent correctly determined that collection           
          efforts should proceed.                                                     
               To reflect the foregoing,                                              


                                                   Decision will be entered           
                                              for respondent.                         
































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