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written advice on which he relied and to which he can attribute
his failure to pay timely his tax liabilities for 1996 and 1997.
Conclusion
The Court has considered all of petitioner’s contentions,
arguments, and requests, and to the extent they were not
discussed, the Court concludes that they are moot, irrelevant, or
without merit.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
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