James C. and Jane A. Wetzel - Page 5

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          portion of the $475 overpayment because section 6402 was not                 
          applied correctly by respondent, they have not met their burden              
          of proof.  Rule 142(a).                                                      
                                                   Decision will be entered            
                                              for respondent.                          

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Last modified: May 25, 2011