Magellean Askew, Jr. - Page 18

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                                     Conclusion                                       
                We have considered all of the other arguments made by                 
          petitioner, and, to the extent that we have not specifically                
          addressed them, we conclude that they are without merit.                    
                Reviewed and adopted as the report of the Small Tax Case              
          Division.                                                                   
                To reflect our disposition of the disputed issues,                    


                                                  Decision will be entered            
                                              for respondent.                         





























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