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challenge in a succeeding year what was overlooked or condoned in
previous years. See, e.g., Rose v. Commissioner, 55 T.C. 28,
31-32 (1970). The closing notice that petitioner received in
2001 does not affect the outcome of this case.
Respondent’s determination is sustained. In reaching our
holding, we have considered all arguments made, and, to the
extent not mentioned, we conclude that they are moot, irrelevant,
or without merit.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011