Sharon M. Rivera and Richard C. Rivera - Page 13

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               The Court sustains respondent's determination to the extent            
          that petitioners may not deduct expenses allocable to their                 
          rental and personal use of the Truckee property.                            
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
                                                       Decision will be               
                                                  entered under Rule 155.             


































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