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trial. We are reluctant to find that respondent abused her
discretion here when, for all the record shows, she was not even
timely requested to exercise it. See Wilson v. Commissioner,
T.C. Memo. 1995-525 (citing Haught v. Commissioner, T.C. Memo.
1993-58; Lapin v. Commissioner, T.C. Memo. 1990-343, affd.
without published opinion 956 F.2d 1167 (9th Cir. 1992).
Accordingly, respondent is sustained on this issue.
Decision will be entered
for respondent.
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