Frank J. Zavatto - Page 6

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               We understand that under the circumstances of this case, the           
          relief mechanism provided by section 86(d)(2) might not seem                
          meaningful to petitioner.  Nevertheless, the deficiency here in             
          dispute properly takes into account the provisions of section               
          86(d)(2), as well as the other applicable provisions of section             
          86.  Therefore, the deficiency must be sustained, and we so hold.           
               To reflect the foregoing,                                              
                                                  Decision will be                    
                                             entered for respondent.                  

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