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               In determining that petitioner sustained the loss in 1995,             
          respondent seems to have adopted the position that petitioner               
          sustained a loss from the worthlessness of operating authorities            
          in a year in which those operating authorities did not exist.  We           
          do not find respondent's position reasonable.                               
               To reflect the foregoing,                                              
                                             Decision will be entered for             
                                        petitioner.                                   
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