Gerald J. and Gayle R. Martinez - Page 8

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            of establishing that respondent's determinations under sections                             
            6651, 6653(a), and 6654 are erroneous.   See Adams v. Commis-                               
            sioner, supra.3                                                                             
                  Based on our examination of the entire record before us, we                           
            find that petitioners have not satisfied their burden of showing                            
            error in any of respondent's determinations in the notices.4                                


                                                             Decision will be entered                   
                                                       for respondent.                                  






















            3  See also Lull v. Commissioner, T.C. Memo. 1978-74, affd. per                             
            curiam 602 F.2d 1166 (4th Cir. 1979).                                                       
            4  We have considered all of petitioner's arguments that are not                            
            discussed herein, and we find them to be without merit.                                     




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