Emmett I. and Shirley Sindik - Page 10

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               Petitioners presented no evidence that there was substantial           
          authority for the treatment of any item or that any item was                
          adequately disclosed on their returns for the years at issue.               
          Accordingly, respondent is sustained on this issue.                         
               To reflect the foregoing,                                              
                                                  Decision will be                    
                                             entered under Rule 155.                  


































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