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a consequence, we are satisfied that respondent has met his
burden of production with respect to this issue. As petitioners
do not argue, nor do we find, that Harlan qualifies for an
exception listed in section 6654(e), respondent’s determination
is sustained.
VIII. Conclusion
We have considered all remaining arguments made by the
parties for contrary holdings and, to the extent not addressed,
find them to be irrelevant, moot, or meritless.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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