Johnny and M. Suzan Black - Page 8

                                         -7-                                          
               We are satisfied that respondent did not abuse his                     
          discretion in making his determination.                                     
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               To give effect to the foregoing,                                       

                                             An appropriate decision will             
                                        be entered for respondent.                    

































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