Janet S. Shapiro - Page 6

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          determining that petitioner is entitled to a refund with respect            
          to her 1996 tax.                                                            
               Reviewed and adopted as the report of the Small Tax Case               
               To reflect the foregoing,                                              
                                             A decision will be entered for           
                                   respondent as to the deficiency in the             
                                   reduced amount agreed to and as to the             
                                   overpayment for 1996 and for petitioner            
                                   as to the additions to tax.                        

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