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to only the evidence the Commissioner did have. Negoescu is just
that sort of taxpayer. After asking the IRS for relief, she gave
the Commissioner no information to help him decide her case.
Once she filed her petition with us, however, she was forthcoming
with exhibits and testimony so that we could make an informed
decision. But our decision would be the same even if we limited
our review to the record that the Commissioner had.
Decision will be entered for
the respondent.
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Last modified: May 25, 2011