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Since petitioner did not engage in a prohibited transaction,
he is not liable for the first tier excise-tax, the second-tier
excise tax, or the additions to tax determined by respondent.
See secs. 4975(a) and (b), 6651(a)(1). We have
considered all arguments made by respondent for a contrary
holding and, to the extent not discussed above, find them to be
without merit.
To reflect the foregoing,
Decision will be entered
for petitioner.
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Last modified: May 25, 2011