David A. Demetree - Page 5

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          family does not diminish the reasonableness of respondent’s                 
          position.  See Wasie v. Commissioner, supra.  Note also that we             
          sustained respondent’s determinations that petitioners had                  
          unreported interest income, were not entitled to certain losses,            
          were liable for self-employment tax, failed to file tax returns,            
          failed to make estimated tax payments, and failed to maintain               
          adequate books and records relating to the years in issue.                  
               Contentions we have not addressed are irrelevant, moot, or             
               To reflect the foregoing,                                              

                                                    Appropriate orders and            
                                             decisions will be entered.               

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Last modified: November 10, 2007