John Boreta - Page 6

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          sustain respondent’s determination of the addition to tax under             
          section 6661.                                                               
               Prior to submission of this case for decision, petitioner              
          filed a motion for partial summary judgment.  Because the issues            
          raised therein have been decided in this opinion, petitioner’s              
          motion for partial summary judgment will be denied as moot.                 
               To reflect the foregoing,                                              

                                                  Petitioner’s motion for             
                                             partial summary judgment will            
                                             be denied as moot, and                   
                                             decision will be entered for             
                                             respondent.                              

























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