Edward A. Birts - Page 11




                                       - 10 -                                         
               In view of the foregoing, we hold that petitioner is liable            
          for the alternative minimum tax.                                            
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               In order to reflect the foregoing,                                     


                                                  Decision will be entered            
                                             for respondent.                          


































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