Marcus C. Seay - Page 4

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          petitioner provide any evidence that the amounts or the                     
          deficiencies determined by respondent therefrom were other than             
          as respondent has determined.  Accordingly, we hold that no                 
          genuine issue of material fact exists requiring trial and                   
          respondent is entitled to summary judgment.                                 
               We have considered all of petitioner’s contentions, and, to            
          the extent they are not addressed herein, they are irrelevant,              
          moot, or without merit.                                                     
               To reflect the foregoing,                                              

                                             An appropriate order and                 
          decision will be entered.                                                   

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