Keith Chiosie - Page 9




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          with applicable law.  Rather, the resolution of such issue                  
          requires us to focus on relevant facts and circumstances that               
          existed at the time that petitioner filed his 1997 return.                  
               In view of the foregoing, we sustain respondent's                      
          determination on this issue.                                                
          Conclusion                                                                  
               To give effect to our disposition of the disputed issues,              


                                             Decision will be entered                 
                                        for respondent.                               






























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