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Yes, provided you use up-to-date SGML software which knows about the WebSGML Adaptations TC to ISO 8879 (the
features needed to support XML, such as the variant form for EMPTY elements; some aspects of the SGML Declaration
such as NAMECASE GENERAL NO; multiple attribute token list declarations, etc).
An alternative is to use an SGML DTD to let you create a fully-normalised SGML file, but one which does not use
empty elements; and then remove the DocType Declaration so it becomes a well-formed DTDless XML file. Most SGML
tools now handle XML files well, and provide an option switch between the two standards.
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