Howard E. Clendenen - Page 11




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          contribution and $9,000 treated as an employer contribution for             
          taxable year ended June 30, 1987.  The source of many of                    
          petitioners’ calculations; i.e., figures for taxable years ended            
          June 30, 1984 and 1985, is unclear, and such figures are not                
          reflected in the instant records.  The declaratory judgment                 
          clearly examined the years at issue.  We do not question those              
          calculations.  We therefore shall grant respondent’s motions for            
          entry of decision.                                                          
               In reaching all of our holdings herein, we have considered             
          all arguments made by the parties, and, to the extent not herein            
          discussed, we conclude them to be irrelevant or without merit.              
               To reflect the foregoing,                                              
                                                  Appropriate orders and              
                                             decisions will be entered.               
























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