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In the absence of a valid issue for review, the Court
concludes that respondent is entitled to judgment as a matter of
law sustaining the notice of determination dated July 22, 2005.
The Court will grant respondent’s motion for summary judgment.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
An appropriate order and
decision will be entered.
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Last modified: May 25, 2011