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Johnson v. Commissioner, 115 T.C. 210 (2000), in support of their
argument that they may use actual substantiation in addition to
deemed substantiation, is misplaced. We reiterate that Johnson
deals with section 4.03 of the revenue procedures, which is not
at issue in this case.
In reaching all of our holdings herein, we have considered
all arguments made by the parties, and to the extent not
mentioned above, we find them to be irrelevant or without merit.
To reflect respondent’s mathematical error in the statutory
notice of deficiency with respect to the adjustments made to
Continental for 1996,
Decisions will be entered
under Rule 155.
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