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Commissioner, T.C. Memo. 1996-512; Porter v. Commissioner, T.C.
Memo. 1996-475.2
Decision will be entered
for respondent.
2 Petitioner argues that the burden of proof is on respondent.
See sec. 6201(d). The resolution of this case does not depend on
which party has the burden of proof.
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Last modified: May 25, 2011