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dischargeability issue? We would have an obligation and a
responsibility to enter a decision sustaining or rejecting in
whole or in part the collection action set forth in the notice of
determination. We would not be fulfilling that obligation and
that responsibility if we were to request the taxpayer to ask the
Bankruptcy Court to resolve a question over which we have concur-
rent jurisdiction.
Our request to that effect would be inconsistent with the
goals of judicial and party economy embodied in the slogan “one-
stop shopping”. If we have jurisdiction to resolve the bank-
ruptcy dischargeability issue, we should not ask the taxpayer who
raises that issue at an Appeals Office hearing and in this Court
to go to another court to resolve that issue and then return to
this Court so we can decide, at the end of what will by then have
become a very long figurative day, whether respondent may proceed
with the collection action as determined in the notice of deter-
mination.
Even if the taxpayer were willing to go back to the Bank-
ruptcy Court, it would be a waste of time and money to try to
force or allow them to do so. The money would consist not only
of additional legal fees but also of additional interest accruing
while the liability remains unpaid. And if the taxpayers are
willing, for purposes of delay, to take these extra steps and to
incur the additional costs, the IRS should not be impeded further
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