Margie E. Robertson - Page 4

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          required to refrain from eating during work hours, she was able             
          to engage in “substantial gainful activity”.  Sec. 72(m)(7);                
          Dwyer v. Commissioner, 106 T.C. 337, 341 (1996).                            
               Accordingly, we sustain respondent’s determinations.                   
          Contentions we have not addressed are irrelevant, moot, or                  
          meritless.                                                                  
               To reflect the foregoing,                                              


                                                   Decision will be entered           
                                              for respondent.                         





























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