Memorandum Opinion
DAWSON, Judge:
This case was assigned to and heard by Commissioner James M. Gussis. This Court agrees with and adopts his opinion which is set forth below.
Opinion of the Commissioner
Respondent's motion for judgment on the pleadings filed on April 14, 1975, pursuant to Rule 120, Tax Court Rules of Practice and Procedure, is presently before the Court.
Respondent determined a deficiency...
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