Charles Levine Preston - Page 8

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          6654(e)(2) and is, therefore, not liable for the section 6654               
          addition to tax.                                                            
               The Court has considered all other arguments advanced by the           
          parties, and, to the extent such arguments have not been                    
          specifically addressed, the Court concludes they are without                
          merit.                                                                      
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   

          Decision will be entered for                                                
          respondent for the deficiency and the                                       
          section 6651(a)(1) addition to tax and                                      
          for petitioner for the section 6654(a)                                      
          addition to tax.                                                            























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