James V. & Melinda S. Edmiston - Page 4

                                        - 4 -                                         
               Petitioner has failed to carry his burden of proof and                 
          respondent's determinations are therefore sustained.                        
               To reflect the foregoing,                                              
                                             An appropriate order and                 
                                        decision will be entered for                  
                                        respondent.                                   

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