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Commissioner, T.C. Memo. 1997-156; Berst v. Commissioner, T.C.
Memo. 1997-137; Martinez v. Commissioner, T.C. Memo. 1997-126;
Fredrickson v. Commissioner, T.C. Memo. 1997-125. We hold
similarly today. Petitioner has presented no new arguments which
would change our view on the instant issue, and we continue to
adhere to our view as espoused in those memorandum opinions for
the reasons stated therein.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011