Julian W. Mandody - Page 4

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          Commissioner, supra at 821; Jacklin v. Commissioner, supra at               
          344.                                                                        
               We further note that respondent objected to the admission of           
          four documents received at the Court hearing, on the grounds that           
          they were not part of the administrative record.  Petitioner                
          credibly testified that all of these documents had been provided            
          to the IRS at some point (possibly before the section 6330                  
          hearing) and that at least some of these documents were submitted           
          to the settlement officer as part of the section 6330 hearing.              
          Accordingly, the issue of what documents should be contained in             
          petitioner’s administrative record also is in dispute.                      
               Material facts remain in dispute.  Accordingly, summary                
          judgment is inappropriate at this juncture.                                 
               To reflect the foregoing,                                              

                                                  An appropriate order will           
                                             be issued.                               


















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