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In sum, we hold that the retroactive application of the 1998
amendment does not deny petitioner due process of the law; thus,
it is constitutional.
In reaching our conclusions, we have considered all of
petitioner’s arguments (namely, whether: (1) The doctrine of
estoppel applies; (2) the duty of consistency owed to petitioner was
violated; and (3) events that occurred before the issuance of the
notice of deficiency may be considered) for a result contrary to
that expressed herein, and to the extent not discussed above, find
them to be without merit.
To reflect the foregoing,
Decision will be
entered for respondent.
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