the Commissioner's determination must be upheld unless it is clearly unlawful. See Thor Power Tool Co. v. Commissioner, 439 U.S. 522, 532-3 (1979), RCA Corp. v. United States, 664 F.2d 881, 886 (2nd Cir. 1981). IRC § 481(a) requires those adjustments necessary to prevent amounts from being duplicated or

ach Samsung Electronics Co. 170MP, 1T' LCD Monitor In accordance with manufacturers Owner's Instructions P/N BN68-00108E-01 dated 1999. Installed a RCA Corp. PROSCAN Model PS8680Z Digital Video Disk Player in accordance with manufacturers Users Manual Manual No. TOCOM 15346010 dated 1998. The LCD monitor