Chi Wai - Page 15

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          the IRS, which petitioner maintains is relevant to respondent’s             
          exercise of discretion in this case “under the public policy                
          prong of the effective tax administration standard.”  At the                
          hearing, we took the motion under advisement.                               
               Petitioner’s motion appears to be in support of a convoluted           
          argument made on brief that respondent should settle petitioner’s           
          case on the basis of the result petitioner would have obtained              
          had she and her husband filed a joint return for the year 2000,             
          which, in fact, they did not do.  We find this argument                     
          irrelevant and unconvincing, and petitioner’s oral motion will be           
          denied.                                                                     
               Respondent may proceed with the proposed levy.                         

                                             Order and Decision will be               
                                        entered for respondent.                       





















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