- 39 -
petitioners intended to abandon the issue, but in any case
respondent's determination of the applicable penalty as to these
items must be sustained as petitioners have failed to satisfy
their burden of proof on this issue.
To reflect the foregoing,
Decision will be entered
under Rule 155.
Page: Previous 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 Last modified: May 25, 2011