Fred F. Humble - Page 8




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          determinations.  Contentions that we have not addressed are moot,           
          irrelevant, or meritless.                                                   
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               To reflect the foregoing,                                              


                                                  Decision will be entered            
                                             under Rule 155.                          

































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