Thai V. Pham and Khuy T. Bui - Page 21

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          support of their position.  Having failed to present sufficient             
          evidence as to the substantial authority upon which they relied,            
          we find that petitioners have not carried their burden.                     
          Accordingly, respondent is sustained as to this issue.                      
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                            under Rule 155.                           
                                                                                     
                                                                                     































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