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events precipitating delay to determine whether the time limits
may be waived or extended”).
We have considered all of the other arguments made by the
parties, and, to the extent that we have not specifically
addressed them, we conclude they are without merit.
In conclusion, we think it appropriate to observe that we
found taxpayers to be very conscientious taxpayers who obviously
take their Federal tax responsibilities quite seriously. We are
sympathetic to the hardship that Mrs. Rehberg’s medical condition
has brought to petitioners’ lives, and we acknowledge that
petitioners used their capital gains for laudable purposes.
Nevertheless, we are constrained to grant respondent’s motion
based on the applicable law.
For the reasons stated, we shall grant respondent’s motion
for partial summary judgment and deny petitioners’ motion for
partial summary judgment.
In closing, we note that petitioners have offered a
collection alternative in the form of an offer in compromise,
which respondent is currently evaluating. If the parties are
unable to agree on this (or another) collection alternative, then
the Court will, in due course, calendar this case for trial on
all relevant issues other than the existence or amount of
petitioners’ underlying tax liability.
Reviewed and adopted as the report of the Small Tax Case
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