- 83 -
We have considered all arguments made by the parties for
contrary holdings and, to the extent not discussed above, find
them to be irrelevant or without merit.
To reflect the foregoing,
Decision will be entered for
petitioners in docket Nos. 2544-94,
2546-94, 5755-94, 5893-94, and
9229-94; decision will be entered
for respondent with respect to the
deficiencies and for petitioners
with respect to the penalties in
docket Nos. 2545-94 and 9230-94; an
appropriate decision for respondent
will be entered in docket No.
5754-94 as to the deficiency and
the addition to tax under section
6651(a)(1) and for petitioner with
respect to the penalty.
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