Craig F. and Lynn M. Rehberg - Page 12

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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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