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                    a.   Longstanding Case                                            
               Petitioner asserts that the legislative history requires               
          respondent to resolve “longstanding” cases by forgiving penalties           
          and interest which would otherwise apply.  Petitioner argues                
          that, because this is a longstanding case, respondent abused his            
          discretion by failing to accept their offer-in-compromise.                  
               Petitioner’s argument is essentially the same considered and           
          rejected by the Court of Appeals for the Ninth Circuit in Fargo             
          v. Commissioner, 447 F.3d at 711-712.  See also Keller v.                   
          Commissioner, T.C. Memo. 2006-166; Barnes v. Commissioner, supra.           
          We reject petitioner’s argument for the same reasons stated by              
          the Court of Appeals.  We add that petitioner’s counsel                     
          participated in the appeal in Fargo, as counsel for the amici.              
          On brief, petitioner suggests that the Court of Appeals knowingly           
          wrote its opinion in Fargo in such a way as to distinguish that             
          case from the cases of counsel’s similarly situated clients                 
          (e.g., petitioner), and to otherwise allow those clients’                   
          liabilities for penalties and interest to be forgiven.  We do not           
          read the opinion of the Court of Appeals in Fargo to support that           
          conclusion.  See Keller v. Commissioner, supra; Barnes v.                   
          Commissioner, supra.                                                        
               Respondent’s rejection of petitioner’s longstanding case               
          argument was not arbitrary or capricious.                                   
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