Peter Spuler, Jr. - Page 14

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          section 7491(c).  We conclude that petitioner’s actions were not            
          those of a reasonable and prudent person under the circumstances.           
          Thus, we sustain respondent on this adjustment.                             
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               To reflect the foregoing,                                              
                                                   Decision will be entered           
                                             under Rule 155.                          
































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