George and Elam Campbell - Page 23

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            5.    Conclusion                                                                             
                  In view of the foregoing, we conclude that section 72(e)(6),                           
            when considered in conjunction with its legislative history and                              
            all of the facts and circumstances peculiar to this case,                                    
            provides a basis in petitioner's excess contribution.                                        
                  In order to give effect to our disposition of the disputed                             
            issue, as well as the parties' concessions,                                                  


                                                             Decision will be entered                    
                                                       under Rule 155.                                   

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