Per Curiam.
The auditor did not file a notice of appeal, but in his brief as an appellee he argues for reversal of the BTA's decision. Sua sponte, the court strikes the auditor's brief.
The primary difference between this case and case No. 96-934 is that in this case the seller was the appellant at the BTA, while in case No. 96-934 the BOE was the appellant. Here, Zell, as the appellant, bore the burden of proving his right to a reduction in...
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