-45-
We note that, if the revocation, which occurred years after
the last of the years in issue, had been made prospective only,
then the revocation would have been little more than a
meaningless act.
We conclude that (1) the retroactivity of the revocation is
not an abuse of discretion when tested by section 7805(b), and
(2) the retroactivity is not an abuse of discretion when tested
by section 601.201(n)(6), Statement of Procedural Rules. See
Capitol Federal Savings & Loan v. Commissioner, 96 T.C. at 217-
219, 223.
We hold for respondent on this issue. To take into account
the foregoing and petitioner’s concession noted supra in note 1.
Decision will be entered
for respondent.
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