- 11 -
72(t). Accordingly, we sustain respondent’s determination on
this issue.
Conclusion
We have considered all of the other arguments made by
petitioners, and, to the extent that we have not specifically
addressed them, we conclude that those arguments are contrary to
the legislative mandate.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect our disposition of the disputed issue, as well as
petitioners’ partial concession, see supra note 2,
Decision will be entered
for respondent.
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Last modified: May 25, 2011