Pamela O' Rourke - Page 9

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          not the proper tax treatment.  Accordingly, we hold that                    
          petitioner is liable for the section 6661 addition to tax (as               
          determined by respondent using the 10 percent rate) for the 1982            
          tax year.                                                                   
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             for respondent.                          


































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