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unreported gross receipts of $252,006 in 1993, and $338,276 in
1995. Respondent has proved by a preponderance of the evidence
that section 6501(e)(1)(A) applies.
We conclude that the statute of limitations does not bar
assessment of tax for 1993.
To reflect concessions and the foregoing,
Decision will be
entered under Rule 155.
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