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consider it. Rule 31(a) specifically provides that "The purpose
of the pleadings is to give the parties and the Court fair notice
of the matters in controversy and the basis for their respective
positions." See also Rule 36(b); Seligman v. Commissioner, 84
T.C. 191, 197-199 (1985), affd. 796 F.2d 116 (5th Cir. 1986);
Barber-Greene Americas, Inc. v. Commissioner, 35 T.C. 365, 390
(1960); Kaplan v. Commissioner, 21 T.C. 134, 147 (1953).
To reflect uncontested determinations and our conclusions
with respect to the disputed issues,
Decision will be entered
under Rule 155.
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