Vasquez, J., concurring: I agree with the majority opinion; however, I write separately to address two additional points. 1. We Are Not Invalidating the Regulations The majority opinion does not invalidate section 301.6320-1(d)(2) or 301.6330-l(d)(2), Q A-D6, Proced. Admin. Regs. Contra J. Swift’s dissenting op. pp. 28-29. In both sections…
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