Scott T. Nobles - Page 4

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          have no choice but to sustain respondent’s determination on this            
          point.                                                                      
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               To reflect the concessions,                                            
                                                  Decision will be entered            
                                             under Rule 155.                          

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Last modified: May 25, 2011