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tax liability is not properly placed at issue, the Court will
review the determination of the Commissioner of Internal Revenue
for abuse of discretion. Sego v. Commissioner, 114 T.C. 604, 610
(2000); Goza v. Commissioner, 114 T.C. 176, 181-182 (2000).
Based upon our examination of the entire record before us,
we find that, except for the determinations relating to respon-
dent’s assessment for petitioners’ taxable year 1988 of excessive
amounts of the addition to tax under section 6653(a) and interest
thereon that respondent conceded,3 respondent did not abuse
respondent’s discretion in making the determinations in the
notice of determination under sections 6320 and 6330 with respect
to petitioners’ taxable year 1988.
We have considered all of the contentions and arguments of
the parties that are not discussed herein, and we find them to be
without merit, irrelevant, and/or moot.
On the record before us, we shall grant respondent’s motion.
To reflect the foregoing,
An order granting respondent’s
motion and an appropriate decision
for respondent will be entered.
3In respondent’s motion, respondent states: “Respondent has
taken the necessary steps to abate the [$67,978.11] excess
penalty (i.e., to the extent that it exceeds $2,777.50) and
interest thereon.”
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