- 5 -
not been given, petitioner would have filed for 21 years as being
exempt without some dispute. Rather, it seems more likely that
his file was misplaced at some point in time. Thus, we find that
petitioner prepared and filed the Form 4361 in 1977.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
for petitioner.
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Last modified: May 25, 2011