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deficiencies related to the characterization of the payments from
Dr. Ehrenworth to Mrs. Spector. Respondent did not waive the
section 6661 additions to tax relating to the exemption issue.
The tax related to the exemption issue will not exceed $5,000,
so the section 6661 additions will not apply.
To reflect concessions and the foregoing,
Decisions will be entered
under Rule 155.
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