JAMES T. FOLEY, Chief Judge.
This petition for review, as presented by the government in its briefing, poses only questions of law. The amount of money that would come to the government coffers if it is successful in the review is minimal, but I will assume — although frankly there is no persuasive showing to so conclude — that the decision of the Referee may have serious impact on the administration of the Internal Revenue Code provisions in their application...
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