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Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered in
docket No. 4692-03S for respondent,
and decision will be entered in
docket No. 5428-03S for petitioner
as to the deficiency in income tax
and the accuracy-related penalty
under section 6662, and for
respondent as to the addition to
tax under section 6651.
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Last modified: May 25, 2011