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sections 6511 and 6512 shall be given effect, consistent with
congressional intent, without regard to an individual’s perceived
notion of fairness. Commissioner v. Lundy, supra.
To give effect to our disposition of the disputed matter, as
well as respondent’s concessions,
An order granting
respondent’s motion, as
recharacterized, and decision
will be entered deciding that
there is no deficiency nor any
addition to tax due from, nor
overpayment due to, petitioner
for the taxable year 2001.
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Last modified: November 10, 2007