Memorandum Opinion
HALL, Judge:
Respondent filed a Motion to Dismiss for Failure to State a Claim Upon Which Relief Can Be Granted, pursuant to Rule 40, Tax Court Rules of Practice and Procedure, in this case which involves a deficiency of $3,297.84 in petitioner's 1974 income tax, plus additions to the tax under sections 6651(a), 6653(a), and 6654
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