James E. Wells - Page 8

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                  To reflect the foregoing and the concessions of petitioner,                           


                                                       Decision will be entered for                     
                                                respondent.                                             






























                  3(...continued)                                                                       
            policy.  We shall not address respondent’s argument in light of                             
            our finding that petitioner did not have an agreement with the                              
            U.S. Attorney to apply petitioner’s claimed credit against the                              
            amounts due for the years at issue.                                                         





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