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Based upon our examination of the record before us, we find
that respondent did not abuse respondent’s discretion in making
the determinations in the notice of determination with respect to
petitioners’ taxable years 2000 and 2001.
We have considered all of the contentions and arguments of
the parties that are not discussed herein, and we find them to be
without merit, irrelevant, and/or moot.
On the record before us, we shall grant respondent’s motion.
To reflect the foregoing,
An order granting respondent’s
motion and decision for respondent
will be entered.
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