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6651(a)(2)8.
We 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.
To reflect the foregoing and the concessions of the parties,
Decisions will be entered
under Rule 155.
8The calculation for 1996 of the additions to tax under sec.
6651(a)(1) and (2) is subject to sec. 6651(c)(1).
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