Kevin H. Motley - Page 8




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          evidence sufficient to persuade the Court that respondent’s                 
          determination is incorrect or that an exception applies.  Rule              
          142(a); Welch v. Helvering, supra at 115; see Higbee v.                     
          Commissioner, supra at 447.                                                 
               Petitioner failed to appear and did not introduce any                  
          evidence.  Accordingly, on this issue, we sustain respondent’s              
          determination.                                                              
               C.   Conclusion                                                        
               We have sustained all of respondent's determinations.                  
          Therefore, we will dismiss the case and enter a decision against            
          petitioner.  Rules 123(b), 142(a); Welch v. Helvering, supra at             
          115.                                                                        
               To reflect the foregoing,                                              
                                             An appropriate order and                 
                                        decision will be entered for                  
                                        respondent.                                   




















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