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written, see Estate of Cowser v. Commissioner, 736 F.2d 1168,
1171-1174 (7th Cir. 1984), affg. 80 T.C. 783 (1983), and we may
not rewrite the law because we may “‘deem its effects susceptible
of improvement’”, Commissioner v. Lundy, 516 U.S. 235, 252 (1996)
(quoting Badaracco v. Commissioner, 464 U.S. 386, 398 (1984)).
Accordingly, we must sustain respondent’s determination.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect our disposition of the disputed issue,
Decision will be entered
for respondent.
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Last modified: May 25, 2011