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preclude us from granting respondent's motion for partial summary
judgment. As indicated, to the extent respondent's motion for
partial summary judgment seeks an increase in respondent's
deficiency determination against petitioner for 1976,
respondent's motion will be denied.
To reflect the foregoing,
An appropriate order will be
issued granting in part and denying
in part respondent's motion for
partial summary judgment.
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Last modified: May 25, 2011