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We have considered the parties remaining arguments1 and find
them irrelevant or unnecessary to reach.
To reflect the foregoing,
An appropriate order and
decision will be entered.
1 In the petition, petitioner contends that her husband was
responsible for filing the income tax returns during the years in
issue and that she had no knowledge of any understatement of tax
when she signed those returns. Because the deemed admissions
clearly contradict petitioner's contention, we find that there is
no genuine issue of fact and, accordingly, we shall grant
respondent's motion for summary judgment.
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