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call an offset a “taking tantamount to a levy is disingenuous”);
cf. sec. 301.6330-1(g)(2) Q&A-G3, Proced. & Admin. Regs.
Respondent properly offset petitioner’s 1994 tax liability by
crediting refunds from other years in accordance with section
6402. We hold that respondent did not engage in collection
activity in violation of section 6015(e)(1)(B).
To take account of respondent’s concession,
An appropriate order
will be issued.
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Last modified: May 25, 2011