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will be an overpayment (i.e., petitioner may be entitled to a
refund). See Rosenthal v. Commissioner, T.C. Memo. 2004-89 n.6;
Ziegler v. Commissioner, T.C. Memo. 2003-282.
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 the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011