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Service. Estate of Emerson v. Commissioner, 67 T.C. 612, 617-618
(1977).
The Court is satisfied from the record that petitioners'
payments to the Internal Revenue Service did not include payment
of the tax attributable to the IRA distribution. Accordingly,
respondent is sustained.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
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