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In reaching our holdings, we have considered all arguments
made, and, to the extent not mentioned, we conclude that they are
moot, irrelevant, or without merit.
To reflect the foregoing,
Decision will be entered
for respondent as to the
deficiency in income tax and
for petitioner as to the
addition to tax.
6(...continued)
6651(a)(1), and thus, we do not consider it.
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