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holdings herein, we have considered all arguments made by the
parties, and to the extent not mentioned above, we find them to
be irrelevant or without merit.
To reflect the foregoing,
Decision will be entered
for petitioner.
11(...continued)
27 (2002); Toney v. Commissioner, T.C. Memo. 2003-333; Strong v.
Commissioner, T.C. Memo. 2001-103. Additionally, unlike in the
case at bar, petitioner did not raise the issue of the
OIC/collection alternatives in the complaint in the District
Court case. Skrizowski v. Commissioner, supra at 279, 281 (“The
sole remedy sought in the complaint in this action is an order to
release these liens on real estate of third parties.”).
Furthermore, respondent does not contend that petitioner lacks
standing regarding the OIC/collection alternative issue.
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