John Erwin Hunter II and Alma Esteban Hunter - Page 7

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          nor states a claim upon which relief can be granted.  Because of            
          the absence from the petition of specific justiciable allegations           
          of error and of supporting facts, this Court will grant                     
          respondent’s motion.  See Funk v. Commissioner, supra.                      
          Accordingly, we shall dismiss petitioners’ case and enter a                 
          decision sustaining respondent’s determinations contained in the            
          notice of deficiency for 2001.                                              


                                             An appropriate order of                  
                                   dismissal and decision will be                     
                                   entered.                                           



























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