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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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Last modified: May 25, 2011