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law. Cox v. Commissioner, 126 T.C. 237, 255-256 (2006); Woodral
v. Commissioner, 112 T.C. 19, 23 (1999).
Throughout these proceedings, petitioner has focused solely
on his contentions concerning having filed a 1991 return. While
the Court sympathizes with petitioner’s frustrations in this
regard, what transpired with respect to this return is not
substantively relevant in the current procedural posture. Yet
due to this singularity of focus, petitioner has never advanced
any other issues susceptible to review under section
6330(c)(2)(A). Accordingly, nothing in the record reflects an
abuse of discretion. The Court will grant respondent’s motion
for summary judgment and sustain the proposed collection action.
To reflect the foregoing,
An order granting
respondent’s motion for
summary judgment and decision
for respondent will be
entered.
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Last modified: May 25, 2011