Maria G. Pelayo - Page 8




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          it is not totally clear, we suspect that this structuring was               
          prompted by an attempt to obtain greater earned income credits by           
          a connived separation.  This is the choice that petitioners made,           
          and it is the choice that they must live with.                              
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
                                                  Decisions will be entered           
                                             for respondent.                          


































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