Darryl F. Royster - Page 32




                                       - 31 -                                         
               To reflect the foregoing,                                              

                                             A decision will be entered               
                                         under Rule 155.6                             






























               6 We note, however, if our decision results in an increase             
          in the amount of petitioner’s deficiency or accuracy-related                
          penalty for any year at issue, since respondent did not ask for             
          an increased deficiency in his pleadings, he is limited to the              
          amounts set forth in the notice of deficiency.                              






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Last modified: November 10, 2007