Michael T. Hines - Page 7

                                        - 6 -                                         
               Contentions we have not addressed are irrelevant, moot, or             
          meritless.                                                                  
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
                                                  Decision will be entered            
                                             for respondent.                          

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Last modified: May 25, 2011