- 3 -
Sec. 402(c)(1); Lemishow v. Commissioner, 110 T.C. 110, 112
(1998). Accordingly, respondent’s determinations are sustained.2
Contentions we have not addressed are irrelevant, moot, or
meritless.
To reflect the foregoing,
Decision will be entered
for respondent.
2 Sec. 7491(a) is inapplicable because petitioners failed to
introduce credible evidence within the meaning of sec.
7491(a)(1).
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Last modified: November 10, 2007