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for a deficiency in the amount of $70,783 and an accuracy-related
penalty in the amount of $14,157.
We have carefully considered all of the remaining arguments
that have been made by petitioners for a result contrary to that
expressed herein, and, to the extent not discussed above, we find
that such arguments are irrelevant or without merit.
To reflect the foregoing,
Decision will be entered for
respondent.
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Last modified: May 25, 2011