Universal Marketing, Inc. - Page 17




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          (asset class 27.0).  Therefore, the Court finds that the                    
          equipment petitioner purchased with the $80,000 was 7-year                  
          property with a 7-year recovery period.  See sec. 168(c), (e)(1);           
          Thomson v. Commissioner, T.C. Memo. 1999-371.                               
               The Court, in reaching its holding, has considered all                 
          arguments made and concludes that any arguments not mentioned               
          above are moot, irrelevant, or without merit.                               
               To reflect the foregoing,                                              

                                             Decision will be entered                 
                                        under Rule 155.                               





























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