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taxpayers, such as petitioners herein, who have relied on revenue
rulings to structure their transactions. Moreover, it is highly
inequitable to impose penalties, which respondent has done in
this case. Accordingly, in this case, we shall not permit
respondent to argue against his revenue ruling, and we shall
treat his revenue ruling as a concession.
An appropriate order will be
issued granting petitioners’ motion
for partial summary judgment.
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