Janice L. Cardiff, f.k.a. Janice Dunn, Petitioner, and Stephen Dunn, Intervenor - Page 8

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          entitled to full relief from the joint and several 1994 income              
          tax liability.                                                              
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
                                                  Decision will be entered            
                                             for petitioner.                          

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