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materials tendered by petitioners. Moreover, the materials
submitted by petitioners show that their situation is,
unfortunately, not unique.
We do not discern in section 7122 an intent of Congress to
override application of specific provisions of the tax laws in
every instance in which the liability is perceived to be unfair
or inequitable. As the Court of Appeals for the Seventh Circuit
observed in Kenseth v. Commissioner, supra, this is not a
feasible judicial function. A fortiori, individual revenue
officers and Appeals officers, carrying out their respective
functions in the IRS collection process, cannot be expected to
engage in the type of statutory interpretation urged on us by
petitioners or to nullify unfortunate consequences of the tax
laws on a case-by-case basis. The terms of section 7122, the
regulations adopted under it, and the Internal Revenue Manual are
consistent with the experience and expertise of IRS personnel in
evaluating financial circumstances. Petitioners do not argue
that the regulations or the Internal Revenue Manual provisions
are invalid. They claim that they were not followed. But terms
such as “promotion of effective tax administration”, “special
circumstances”, and “compelling public policy or equity
considerations” have a narrower meaning than that urged by
petitioners, and the explanations of those terms in the
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