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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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Last modified: May 25, 2011