Steven H. and Anna J. Jensen - Page 9

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          petitioners’ gross income.  Accordingly, we sustain respondent’s            
          determination.                                                              
               We have considered all of the other arguments made by                  
          petitioners, and, to the extent that we have not specifically               
          addressed those arguments, we conclude they are without merit.              
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               To reflect the foregoing,                                              


                                             Decision will be entered                 
                                        for respondent.                               




























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