William H. and Sandra G. Flank - Page 10

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          instead of down to $131,878.  Petitioner contends that                      
          respondent’s inconsistent application of the rounding rules tends           
          to result in a higher tax.                                                  
               The Court finds that even if petitioner is correct, the                
          difference in each calculation is less than $1, and the impact on           
          petitioners’ total tax is negligible.                                       
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               To reflect the foregoing,                                              


                                                  An appropriate order will           
                                             be issued, and decision will             
                                             be entered under Rule 155.               
























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