- 5 -
867, 872 (1981) (quoting San Antonio Indep. Sch. Dist. v.
Rodriguez, 411 U.S. 1, 41 (1973)), affd. in part on this
issue and revd. in part on another issue 697 F.2d 46 (2d
Cir. 1982).
In light of the foregoing we sustain respondent’s
determination.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011