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have been duplicated many times and are in the possession of many
different people and entities, we have serious doubts about the
value asserted by petitioners’ appraiser. However, because
petitioner was not the legal owner of the materials and was not
legally entitled to donate them, we need not reach the valuation
issue.
We have considered all arguments by the parties, and, to the
extent not mentioned, we conclude that they are moot, irrelevant,
or without merit.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: March 27, 2008