Xavier J.R. and Sulochana D. Avula - Page 7




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          sustain respondent’s determinations to disallow the S corporation           
          losses claimed by petitioners for 1993, 1994, and 1995.5                    
               To reflect the foregoing and the concessions of petitioners,           
                                             An appropriate order dismissing          
                                        this case for lack of jurisdiction            
                                        as to the additions to tax                    
                                        determined under section 6654(a) and          
                                        decision for respondent will be               
                                        entered.                                      
























               5We have considered all of the contentions and arguments of            
          petitioners that are not discussed herein, and we find them to be           
          without merit and/or irrelevant.                                            





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