James A. and Corlis L. Perry - Page 11

                                       - 10 -                                         
               To the extent that we have not addressed any of the parties’           
          arguments, we have considered them and conclude they are                    
          irrelevant or without merit.                                                
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   


                                                  Decision will be entered            
                                             under Rule 155.                          































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