Memorandum Opinion
SCOTT, Judge:
Pursuant to notice previously given, respondent's motion for summary judgment in the above-entitled case, filed January 21, 1977, was heard at Los Angeles, California, on March 7, 1977.
The record shows that respondent determined a deficiency in petitioners' income tax for the calendar year 1974 in the amount of $2,196 and an addition to tax under section 6653(a), I.R.C. 1954,
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