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met this standard when Cox reopened petitioner’s collection case
or that the Commissioner otherwise improperly inspected
petitioner’s books or records more than once for a taxable year.
Nor have petitioners cited any authority (and we are not aware of
any such authority) that states that the Commissioner may not
reopen a closed collection case on the basis of information that
at the time of reopening tends to show that the amount previously
considered uncollectible may in fact be collectible. Given the
additional fact that petitioner never resisted giving information
to Cox after he had reopened his collection case, but in fact
gave it to him voluntarily, we conclude that Cox by reopening the
collection case did not perform a prohibited second inspection of
petitioner’s books and records in violation of section 7605(b).
See United States v. Baker, 451 F.2d 352 (6th Cir. 1971); cf.
Miller v. Commissioner, T.C. Memo. 2001-55.
We sustain respondent’s determinations except to the extent
of his concessions. We have considered all arguments made by the
parties and have rejected those arguments not discussed herein as
meritless. In order to reflect the foregoing, including
respondent’s concessions,
An order will be issued
denying petitioners’ motion,
and decisions will be entered
under Rule 155.
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